OSHA Answers Employee Vaccination Questions

By Cass Jacoby, RCS Reporter.  

New OSHA guidance on employee vaccinations distinguishes difference between “required” and “recommended” vaccinations.  

This past April, the Occupational Safety and Health Administration released new FAQ information guiding employers through considerations for recommending or requiring employees to receive COVID-19 vaccines.  

As reported by the NRCA, the new guidance highlights the differences in OSHA standards when employers specifically require employee vaccinations.  

According to OSHA, adverse reactions to the vaccine are classified as “work related” if employers require employees to be vaccinated. Employer’s requiring vaccinations must alert OSHA within 24 hours of employee inpatient hospitalization from an adverse reaction.  

Even if the adverse reaction does not lead to hospitalization, the reaction must be recorded on the employers OSHA 300 log if it meets the other general criteria of OSHA’s recordkeeping requirements, such as days away from work. So, if an employee has fever and chills following the vaccine and uses a sick day, the reaction must be recorded. But actions like an employee only needing over-the-counter medication to ease soreness at the injection site do not need to be recorded.  

Employers who recommend rather than require vaccination do not need to record adverse reactions nor do they need to report hospitalizations. The vaccine in this instance must be truly voluntary. This discretion is to provide clarity surrounding OSHA expectations to record adverse reactions during a health emergency, it doesn’t change the responsibilities of an employer under OSHA’s recordkeeping regulations.  

Employers recommending a vaccine may help make the vaccine available to employees or make arrangements for employees to get a vaccination at an offsite location. It has been ruled that the method by which an employee receives a recommended vaccine doesn’t matter for the sake of this question.  

Read OSHA’s new FAQs for more information. 

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