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12.22.2025 Legal News

OSHA Provides Guidance on Measles Exposure in the Workplace

Summary — CDC data show increased measles activity nationwide in 2025, with nearly 2,000 confirmed cases. OSHA considers measles a workplace hazard, particularly for unvaccinated adults, with elevated risks in certain settings. Employers may have obligations under OSHA recordkeeping, PPE, bloodborne pathogens, hazard communication, and the General Duty Clause, and may wish to review compliance programs and ensure timely reporting of measles-related hospitalizations.


As of December 16, 2025, the United States Center for Disease Control (CDC) reported a total of 1,958 confirmed measles cases in the United States, see here. And, CDC has stated there have been 49 “outbreaks” reported in 2025, and 88% of confirmed cases (1,713 of 1,958) are outbreak-associated. Most of these are limited to children.

Federal OSHA reports measles outbreaks are a hazard in the workplace, as well. “Measles…is a highly contagious, vaccine-preventable respiratory illness…that may infect adults who have not been vaccinated or have never had the disease.” OSHA notes, adult workers may be exposed to measles whenever the virus is circulating in the community. Certain workplace environments increase the likelihood of worker exposure to measles, including:

  • Healthcare settings (clinics, hospitals, nursing homes)
  • Clinical and research laboratories
  • Congregate settings (schools, daycares, dormitories, assisted living facilities, detention facilities)
  • High-density workplaces such as meatpacking plants
  • Living and conducting work outside of the United States

Employers cannot ignore OSHA requirements triggered when employees contract measles in the workplace. OSHA guidelines indicate measles exposure may trigger four concerns under OSHA Standards:

OSHAs Recordkeeping and Reporting Occupational Injuries and Illness.
Measles contracted in the workplace is a recordable illness. OSHA guidance states the measles virus satisfies the definition in 29 CFR 1904, Subpart C, of “illness requiring medical treatment beyond first aid” and is recordable. If an employee with occupationally acquired measles is hospitalized, OSHA must be notified within 24 hours as indicated in CFR 29 1904 Subpart E.

OSHA's Personal Protective Equipment (PPE) Standards.
General industry Standard, 29 CFR 1910 Subpart I, and Construction Standard, 29 CFR 1926, Subpart E, require every employer assess the workplace to determine if hazards are present, or are likely to be present, and select PPE that will protect affected employees. The employer must provide this PPE and train workers how to use it. For measles, selected PPE may include gloves, eye and face protection, and respiratory protection, as determined by the task and hazards identified.

OSHA’s Bloodborne Pathogens (BBP) Standard.
The BBP Standard (29 CFR 1910.1030) applies to occupational exposure to human blood and other potentially infectious materials. The BBP standard would be triggered where employees are exposed to infectious materials in a manner that transmits measles. The BBP standard describes measures that could serve as a framework to control non-bloodborne exposures, including preventing exposure to body fluids (e.g., sputum, respiratory and nasal secretions, and saliva, outside of dental procedures) to which the standard does not apply.

The General Duty Clause.
Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), requires employers to furnish to each worker "employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm."

Hazard Communication Standard.
The Hazard Communication Standard requires all employers protect their workers from exposure to chemicals used for cleaning and disinfection. Employers should be trained and advised that common sanitizers and sterilizers could contain hazardous chemicals. Where workers are exposed to hazardous chemicals, employers must comply with OSHA's Hazard Communication standards (in general industry, 29 CFR 1910.1200 and, in construction, 29 CFR 1926.59) and other applicable OSHA chemical standards. OSHA provides information about hazardous chemicals used in hospitals in the housekeeping section of its Hospital eTool.

To mitigate potential for OSHA enforcement and protect adult workers from exposure to measles, companies may want to take the following measures:

Measure No. 1: Audit facility compliance with OSHA Recordkeeping (OSHA 300 logs), PPE, BBP, and Hazard Communication, targeting compliance with transmissible disease requirements.

Measure No. 2: Provide medical testing and assistance when requested for employees concerned about exposure to measles outside the workplace and isolate those employees from the workplace, who have tested positive for the virus.

Measure No. 3: Report to OSHA via e-form within 24 hours of an employee being hospitalized due to measles.

Key Takeaways

  • Rising Public Health Risk – Increased measles activity in 2025, including widespread outbreaks, underscores the heightened risk of workplace exposure, particularly for unvaccinated adult workers.

  • Workplace Hazard Recognition – OSHA considers measles a recognized workplace hazard, with elevated exposure risks in healthcare, congregate living, high-density, laboratory, and internationally connected work environments.

  • Multiple OSHA Standards Implicated – Occupational measles exposure may trigger compliance obligations under OSHA recordkeeping and reporting rules, PPE requirements, the Bloodborne Pathogens Standard, the Hazard Communication Standard, and the General Duty Clause.

  • Employer Preparedness and Response – Employers may help protect workers and limit enforcement risk by reviewing OSHA compliance programs, supporting employees who may have been exposed, and timely reporting measles-related hospitalizations to OSHA.