Employers Don’t Have to Record Adverse Vaccine Reactions on Their OSHA Logs
By Nicole L. Stangl and Ruder Ware Alumni
May 26, 2021
OSHA has changed course and is now advising employers they do not need to record employees’ adverse reactions to COVID-19 vaccines on their OSHA logs. A month ago, OSHA’s position was adverse vaccine reactions had to be recorded as illnesses if an employer required its employees to be vaccinated. The new guidance now relieves employers of that requirement, regardless of whether they require vaccination or not. This policy is to remain in effect through May 2022.
OSHA’s stated reason for the change in position is to avoid the appearance of discouraging workers from getting vaccinated or to “disincentivize employers’ vaccination efforts.”
OSHA’s new guidance may be found at www.osha.gov/coronavirus/faqs#vaccine. For links to our previous articles on this subject and more in-depth discussion of employer responsibilities for recording and reporting illnesses and injuries, see the article It Looks Like a Mandatory COVID-19 Standard Will be Coming, and OSHA Clarifies Recording Adverse Vaccine Reactions.
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