Tuberculosis case recordkeeping

You must record the case on the OSHA 300 Log when an employee who was occupationally exposed to a known case of active tuberculosis subsequently develops a tuberculosis infection, shown by a positive skin test or a diagnosis by a physician or other licensed health care professional. See Recording criteria for work-related tuberculosis cases at 1904.11(a).

• Record the case by checking the "respiratory condition" column on the OSHA 300 Log as described in 1904.11(a).

No — a positive TB skin test obtained at a pre-employment physical does not have to be recorded on your OSHA 300 Log because the employee was not occupationally exposed to a known case of active tuberculosis in your workplace at the time the test was taken. See 1904.11(b)(1).

• If the employee later is occupationally exposed at your workplace to a known active TB case and then develops infection, you would record it under 1904.11(a).

Yes — you may line-out or erase a recorded TB case from the OSHA 300 Log if you obtain acceptable evidence that the case was not caused by occupational exposure at your workplace. See 1904.11(b)(2).

• Acceptable circumstances for removing the entry include the specific examples listed in 1904.11(b)(2)(i)–(iii).

You may remove the TB case from the Log if one of the following is shown: the worker lives with someone diagnosed with active TB (household source), the Public Health Department identifies the worker as a contact of an individual with active TB unrelated to the workplace, or a medical investigation shows the infection was caused by exposure away from work or not related to workplace exposure. See 1904.11(b)(2)(i)–(iii).

• These are the three specified circumstances in the standard that permit lining-out or erasing a previously recorded case.

• Keep any supporting documentation used to justify the removal as part of good recordkeeping practice (see 1904 for general recordkeeping requirements).

Yes — if an employee was occupationally exposed to a known case of active tuberculosis and later develops a tuberculosis infection evidenced by a positive skin test, that positive test makes the case recordable on the OSHA 300 Log. See 1904.11(a).

• The standard explicitly treats a positive skin test as evidence of a tuberculosis infection for recording purposes when there was occupational exposure to a known active TB case.

A diagnosis by a physician or other licensed health care professional qualifies for recordkeeping under 1904.11(a). See 1904.11(a).

• For a positive skin test alone, the regulation treats that result as sufficient evidence of a tuberculosis infection when combined with documented occupational exposure to a known active TB case.

No — exposure to a person with latent (non-active) TB is not the trigger; the rule requires occupational exposure to a known case of active tuberculosis to make subsequent infection recordable. See 1904.11(a).

• Only occupational exposure to a known active TB case, followed by a positive skin test or medical diagnosis, makes the case recordable under 1904.11(a).

Yes — if the Public Health Department identifies the worker as a contact of an active TB case that is unrelated to your workplace, you may line-out or erase the case from the OSHA 300 Log under 1904.11(b)(2)(ii).

• Keep documentation of the Public Health Department determination as support for removing the entry.

You may line-out or erase the recorded TB case if a medical investigation shows the infection was caused by exposure away from work or proves the case was not related to workplace exposure, as stated in 1904.11(b)(2)(iii).

• Retain the medical investigation findings as documentation supporting the removal.

No — the original positive pre-employment skin test itself is not recordable by your establishment because it was obtained before any occupational exposure in your workplace; however, if the employee later develops a new infection attributable to a known active TB exposure in your workplace, that new case would be recordable under 1904.11(a). See 1904.11(b)(1).

• The timing and location of occupational exposure determine recordability under 1904.11.

Yes — tuberculosis is treated as a contagious disease that is considered work-related when an employee is infected at work, unlike the common cold or flu which the recordkeeping rule excludes from required recording under certain circumstances. See 1904.11(a) and the OSHA letter clarifying work-related illness exceptions that notes contagious diseases such as tuberculosis are considered work-related if infected at work.

• Employers must investigate suspected TB infections and apply the recording criteria in 1904.11(a).

Yes — you may maintain OSHA injury and illness records, including TB entries, in electronic formats or using software-generated forms provided the electronic records are equivalent to OSHA forms and meet the requirements for equivalent forms and access. OSHA confirmed this in its interpretation allowing software-generated forms that meet the equivalence requirements in Part 1904. See the OSHA interpretation on software-generated OSHA recordkeeping forms and the general recordkeeping provisions at 1904.

• Ensure any electronic or software-generated OSHA 300/300A/301 equivalents contain the same information and are available for inspection and employee access as required by Part 1904.