In a dramatic shift in its enforcement position with respect to the recordability of adverse reactions from COVID-19 vaccines, the Occupational Safety and Health Administration (OSHA) on May 21, 2021, published a new Frequently Asked Question (FAQ) establishing that employers do not need to record adverse reactions from COVID-19 vaccines on their OSHA 300 Logs, at least through May of 2022. The enforcement position applies regardless of whether an employer requires, recommends, or incentivizes employees to receive the vaccine.

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