Is the Flu a Recordable Injury?

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Pandemic Flu Program

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:

  • Cases of seasonal flu does not have to be recorded; but
  • Cases involving special flu strains, like H1N1, apparently are recordable.

Seasonal Flu Not Recordable

Influenza comes in different forms or strains:

  • Seasonal influenza—the common flu; and
  • Novel strains that emerge from time to time, like avian influenza A H5N1 or swine flu, H1N1

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:

    1. It’s a confirmed case of H1N1 as defined by the CDC (Centers for Disease Control), i.e.:
      1. The person has influenza-like illness; and
      2. A lab confirms H1N1 via 1 or more of the following tests via real-time RT-PCR and/or viral culture
      3. The case is work-related under Sec. 1904.5 of the Recordkeeping standard; and
      4. The case involves 1 or more of the recording criteria set out in Sec. 1904.7, i.e.:
      • Death;
      • Days away from work;
      • Restricted work or transfer to another  job;
      • Medical treatment beyond first aid;
      • Loss of consciousness;
      • A significant injury or illness diagnosed by a physician or other licensed health care professional.

Caveats Apply

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:

  • Healthcare workers performing or present during the performance of aerosol-generating procedures on confirmed or suspected 2009 H1N1 patients, such as sputum inductions;
  • Healthcare workers in close contact, i.e., working within 6 feet of suspected or confirmed patients or entering into a small enclosed airspace with the patient; and
  • Staff transporting suspected or confirmed patients in ambulances or other enclosed vehicles.

The directive doesn’t apply to workers with only medium or low exposure risk, including:

  • Employees with high frequency contact with the general population, e.g., teachers or retail workers; or
  • Employees in jobs that don’t require close contact, i.e., within 6 feet of others.

Conclusion

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.

  • admin

    Bottom Line: It’s a pretty good bet to treat such novel strains as being not recordable unless and until OSHA stipulates otherwise.

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