Q: Is influenza a work-related illness that must be recorded in the OSHA 300 under the OSHA Recordkeeping standard?
A: The short answer is that it depends on the kind of flu the worker gets:
Seasonal Flu Not Recordable
Influenza comes in different forms or strains:
The recordkeeping standard 1904.5(b)(2)(viii) itself states that the common cold or flu are not recordable.
H1N1 May Be Recordable
Until 2009, OSHA hadn’t specifically addressed the recordability of novel strains. So the the assumption was that these strains were also unrecordable under Sec. 1904.5(b)(2)(viii). But in November 2009, OSHA issued an enforcement directive on H1N1 that dispels this function.
“Illness due to the 2009 H1N1 influenza is not considered a common cold or seasonal flu,” according to the directive. So it is recordable if:
The OSHA enforcement directive on H1N1 applies only to one novel strain of influenza—the 2009 H1N1—which encompasses the 2009-2010 flu season.
Moreover, it covers only workers deemed to be in occupations that carry a “high” or “very high” risk of exposure, including:
The directive doesn’t apply to workers with only medium or low exposure risk, including:
What we know for sure is that seasonal flu cases are not recordable.
We also know that 2009 H1N1 cases are/were recordable for workers in very-high and high risk jobs. So you might want to go back to your OSHA 300 logs and ensure that H1N1 cases were properly recorded for covered workers during the 2009-2010 flu season.
The last thing we know based on the 2009 directive on H1N1 is that OSHA may stipulate that certain kinds of novel strains of influenza are recordable.