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On May 10, ABC, as a steering committee member of the Construction Industry Safety Coalition, wrote to U.S. Department of Labor’s Occupational Safety and Health Administration urging it to review and revise its recently issued Frequently Asked Questions on whether employers must record adverse reactions caused by COVID-19 vaccinations that are required and/or recommended by employers.

In a letter to Acting Assistant Secretary James Frederick, CISC wrote that it does not object to OSHA’s position that an adverse reaction from a required COVID-19 vaccine would potentially be recordable (assuming all of the recordability criteria are met).  Instead, CISC is concerned with the third FAQ regarding the recordability of adverse reactions to a COVID-19 vaccine when the employer has not required the vaccination. CISC believes the analysis undertaken by OSHA related to the potential recordability of adverse reactions from recommended COVID-19 vaccines is confusing to employers and deviates from a straightforward application of the geographic presumption of OSHA’s recordkeeping rule.

Given the public health importance of encouraging all eligible workers to get vaccinated, CISC is concerned that the confusion created by OSHA’s third FAQ may result in disincentives to vaccinations in the construction industry.

CISC indicated in the letter that the steering committee would be happy to meet with OSHA to further discuss its concerns with OSHA’s response to the third FAQ and any other potential revisions.


Recently, OSHA posted new Frequently Asked Questions on recording illnesses caused by required and/or recommended COVID-19 vaccinations.

The three new FAQs include:

ABC has launched a COVID-19 Vaccine Toolkit as part of the Coronavirus Update webpage to help inform and educate members about the latest available resources and information on COVID-19 vaccines.

For additional information about COVID -19 and vaccines, visit OSHA’s COVID-19 webpage.