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Workplace Law Lowdown | OSHA Abandons Requirement to Record COVID-19 Vaccine Adverse Reactions

By: Alexander J. Burridge, Associate, Workplace Law Practice Group


Employers are no longer required to record employee adverse reactions to COVID-19 vaccines in OSHA 300 Logs.

Guidance issued by the Occupational Safety and Health Administration (“OSHA”) on April 20, 2021 required employers to record adverse reactions to COVID-19 vaccines when an employee’s ability to work was affected. However, on May 22, 2021, OSHA suspended the recording requirement until May of 2022.

OSHA stated that it eliminated employers’ recording requirement for adverse reactions to COVID-19 vaccines to avoid disincentivizing employers’ vaccination efforts and discouraging workers from receiving vaccinations. Without the recording requirement, employers should feel more confident about implementing vaccine policies to further return to work efforts.

The bottom line is, at least until May of 2022, employers do not need to track and record employees’ adverse reactions to COVID-19 vaccines.

Bodman’s Workplace Law Group can assist employers in tailoring a vaccine policy to their needs. Any employer interested in issuing a vaccination policy to its workforce or that has additional questions about OSHA 300 Log recording requirements should contact any member of Bodman’s Workplace Law Group. Bodman cannot respond to your questions or receive information from you without first clearing potential conflicts with other clients. Thank you for your patience and understanding.

Click here to view this update in PDF format.

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