Federal agencies Recordkeeping Workplace exposures

Are adverse reactions to vaccines recordable? OSHA updates COVID-19 FAQ list

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Photo: Remains/iStockphoto

Washington — OSHA is requiring the recording of adverse reactions to COVID-19 vaccines only when vaccination is required by the employer, the agency says in an addition to its series of frequently asked questions on protecting workers from exposure to the coronavirus.

Establishments are required to record an adverse reaction to a vaccine only if the illness is work-related, a new case and meets at least one of OSHA’s general recording criteria in 1904.7. Those criteria include days away from work, restricted work or medical treatment beyond first aid. If a vaccine is required as a condition of employment, any adverse reaction is considered work-related.

For employers who recommend but don’t require a vaccine, any resulting illnesses or adverse effects do not require recording at this time. However, “If employees are not free to choose whether or not to receive the vaccine without fearing adverse action, then the vaccine is not merely ‘recommended.’”


Finally, the agency notes that “recommended but not required” vaccines can apply to scenarios such as making vaccines available at work, helping employees receive vaccines at an offsite location, or offering vaccines as part of a voluntary health and wellness program.

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