Frequently Asked Questions
Can employers conduct work site temperature checks or other health screening?
Yes. Neither the OSH Act nor OSHA standards prohibits employer screening for COVID-19, if applied in a transparent manner applicable to all employees (i.e., non-retaliatory).
Employers may consider implementing strategies to reduce risks to the safety and health of workers and workplaces from COVID-19 that include conducting daily in-person or virtual health checks (e.g., symptom and/or temperature screening, questionnaires, self-checks and self-questionnaires). Any such screening should consider ways to maintain confidentiality, as required by the Americans with Disabilities Act.
What OSHA requirements must an employer follow when conducting health screening, temperature checking, or COVID-19 testing?
If an employer implements health screening or temperature checks and chooses to create records of this information, those records might qualify as medical records under the Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020). The employer would then be required to retain these records for the duration of each worker's employment plus 30 years and follow confidentiality requirements. However, employers need not make a record of temperatures when they screen workers, but instead may acknowledge a temperature reading in real-time.
Personnel administering COVID-19 tests, in-person temperature checks, or other in-person health screening must be protected from exposure to sources of SARS-CoV-2, including asymptomatic and pre-symptomatic workers who might be infected but not know it. Protection of screening and testing workers should follow the hierarchy of controls, including appropriate engineering and administrative controls, safe work practices, and PPE.
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4-5. How can the employer take temperatures for COVID-19 without having to keep records?
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