OSHA Releases Updated Guidance on Recording Adverse Reactions by Employees to COVID Vaccine
The Occupational Safety and Health Administration (OSHA) has released guidance regarding the employer’s obligation to record adverse reactions by employees when they received the COVID-19 vaccine. The guidance addresses the employer’s requirements if a mandatory vaccination policy has been implemented for the workplace. If the employer does require employees to be vaccinated as a condition of employment, then any adverse reaction to the vaccine would be considered work related if the reaction meets the criteria for recordability for OSHA’s Form 300, Log of Work-Related Injuries, and Illnesses.
If a mandatory policy has been implemented, then any adverse reaction is recordable if it led to the employee missing more than one day work, medical attention beyond first aid is required, or the reaction resulted in restricted work or transfer to another job. OSHA has a very specific list of actions that it considers first aid so that list needs to be consulted in determining the recordability of an incident.
Employers that only recommend the vaccine to their employees, but do not require it, are not required to record adverse reactions. To be truly voluntary, the employee’s choice to accept or reject the vaccine cannot have any negative impact on the employee, including any impact on their performance rating or professional advancement. Unless the employee is totally free to choose whether or not to receive the vaccine without fear of adverse action, then the vaccine cannot be considered “recommended.”
For more information on this recording update, or if you have any questions, please contact PRINTING United staff at govtaffairs@printing.org.
Marci Kinter is the Vice President of Government & Regulatory Affairs at PRINTING United Alliance, the largest, most comprehensive member-based printing and graphic arts association in the United States. PRINTING United Alliance members have exclusive access to preeminent education; training; workshops; events; research; governmental and legislative representation; safety and environmental sustainability guidance; and resources from the leading media company in the industry – NAPCO Media.
In this article, Kinter provides information regarding updated OSHA guidances. Reach out to Kinter should you have additional questions specific to how these issues may affect your business: mkinter@printing.org
To become a member of PRINTING United Alliance and learn more about how PRINTING United Alliance subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.
Marcia Kinter is the Vice President, Government & Regulatory Affairs at PRINTING United Alliance. Ms. Kinter oversees the development of resources for the Association addressing environmental, safety & health, and sustainability issues. She represents the printing industry, as well as their associated supplier base, before federal and state regulatory agencies on environmental, safety and other government issues directly impacting the printing industry.
In 2008, Kinter, in conjunction with colleagues from other printing trade associations, was instrumental in launching the Sustainable Green Printing Partnership program. The SGP Program is a registry system for printing facilities that includes third party verification. The program successfully launched as an independent organization in August 2008.
Kinter is a member of and serves as Secretary for the Academy of Screen Printing Technology. In 2001, Kinter received the William D. Schaeffer Environmental Award for significant advancement of environmental awareness in the graphic arts industry.
Before joining PRINTING United Alliance, Kinter worked for The American Waterways Operators, Inc., the national association for the barge and towing industry.
She holds bachelor’s degree in urban planning from the University of Maryland, College Park, and a master’s degree in public administration from George Mason University.
