OSHA Changes Position on Recordability of Adverse Reactions from COVID-19 Vaccines 

Situation Report | June 1, 2021

The Occupational Safety and Health Administration (OSHA) published a new Frequently Asked Question (FAQ) on May 21 establishing that employers do not need to record adverse reactions from COVID-19 vaccines on their OSHA 300 Logs, at least through May of 2022. This is a change from its previous position. 

The FAQs now state: 

DOL and OSHA, as well as other federal agencies, are working diligently to encourage COVID-19 vaccinations. OSHA does not wish to have any appearance of discouraging workers from receiving COVID-19 vaccination, and also does not wish to disincentivize employers’ vaccination efforts. As a result, OSHA will not enforce 29 CFR 1904’s recording requirements to require any employers to record worker side effects from COVID-19 vaccination through May 2022. We will reevaluate the agency’s position at that time to determine the best course of action moving forward.