In a similar vein, the Occupational Safety & Health Administration (OSHA) this week clarified the obligation of employers to report an adverse reaction to the COVID-19 vaccine. In its latest Frequently Asked Questions (FAQ) posting, OSHA added a fourth requirement to its guidance on determining whether an adverse reaction is recordable. The new additional requirement is if the vaccine is required for employees. Prior to this new guidance, the adverse reaction was recordable if it met the following three conditions: (1) it is work-related; (2) is a new case; and (3) meets one or more of the general recording criteria (e.g., days away from work, restricted work or transfer to another job, medical treatment beyond first aid. Consequently, now adverse reactions are only potentially recordable on the OSHA 300 log if the vaccine is required by the employer. Even in cases where an employer has in fact recommended vaccination, an adverse reaction report is not necessary.