Generally, employers have to record their employees’ adverse reactions (i.e., illness or injury) to the COVID-19 vaccine on their 300 logs if the reactions are work-related and meet one or more of the general recording criteria required by OSHA (including days away from work, restricted work or transfer to another job, medical treatment beyond first aid). Adverse reactions are deemed work-related when employers require their employees to be vaccinated for work-related reasons.

Conversely, employers who do not require employees to get vaccinated do not have to record adverse reactions on their 300 logs.  Employer should note that the vaccine must be “truly voluntary” for workers to avoid the recording requirement. This means that the worker’s choice to accept or reject the vaccine must not affect their performance rating or professional advancement, and the employees who do not get the vaccine must not suffer punishment for that choice.

Also, the circumstances by which employees receive a vaccine do not affect the recording requirement. The following examples are ways employers can encourage vaccines without mandating them and triggering the recording requirement:

  • The employer makes the COVID-19 vaccine available to their employees at work;
  • The employer makes arrangements for employees to receive the vaccine at an offsite location (i.e., pharmacy, hospital, local health department, etc.); and/or
  • The employer arranges for the vaccine to be offered as a part of a voluntary health and wellness program at the workplace.

For help with OSHA matters, please call (312) 894-3322 or fill out our contact form.