Alan E. Achatz, CCM, CHE of Club Safety Solutions addresses whether or not a club needs to record adverse reactions to a COVID-19 vaccine on its OSHA 300 log.
OSHA has stated that if you require employees to take the COVID 19 vaccine and your employee has an adverse reaction to the shot, then this is considered a work-related injury and must be recorded.
An adverse reaction to the vaccine will be recordable if the reactions meet the definition of a recordable injury or illness:
1. It is work-related, which OSHA presumes if the vaccine is mandated by the employer;
2. It is a new case; and
3. The illness meets at least one of the general recording criteria in 29 CFR 1904.7 (e.g., days away from work, restricted work or transfer to another job, or medical treatment beyond first aid).
OSHA distinguishes between mandatory vaccines and those that are recommended by an employer. If the vaccine is truly voluntary, OSHA does not require the employer to record an adverse reaction on the employer’s OSHA 300 log. On the other hand, if the employer mandates the vaccine, the employer must record it if it meets the recording criteria.