Measles Is on the Rise. Have You Reviewed Your Vaccine Policies Since Covid?

With the global Covid-19 pandemic in the rear-view mirror, employers are not eager to confront another infectious disease outbreak; they may not have a choice. 2025 had the highest number of measles cases in the US in 20 years, and already in 2026, measles is surging in several states.

Employers should proactively plan to respond to measles outbreaks that affect the workplace.

How much are measles outbreaks increasing?

The US is at risk of losing its measles elimination status, the New York Times reported in January, as 2025 saw the highest number of measles infections in the country in more than two decades. Across 45 states last year, more than 2,200 people were infected with the highly contagious viral respiratory disease. A meeting to review the elimination status of both the US and Mexico has been set for November.

And so far this year, according to the latest available CDC data, as of March 20, there have been nearly 1,500 confirmed cases of measles across the majority of states: Alaska, Arizona, California, Colorado, Florida, Georgia, Idaho, Illinois, Kentucky, Maine, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Texas, Utah, Vermont, Virginia, Washington and Wisconsin. A total of 14 new outbreaks have been reported so far this year, the CDC said, with more than 90% of cases being outbreak-related.

The agency warns that measles can have serious complications including death, hospitalization, pneumonia, swelling of the brain (encephalitis) and pregnancy complications. 

What are the OSHA considerations?

Unfortunately, federal public health guidance from the CDC is limited on the exact steps an employer needs to take if an employee is exposed to or contracts the measles. However, health officials in some locations, including Los Angeles and New Mexico, have conducted contract tracing and worked with employers to protect and inform employees.

While there is no specific OSHA standard covering measles directly, guidance indicates other OSHA standards may apply to the prevention of occupational exposure to measles, creating obligations for employers. Those OSHA standards are the following:

• Record keeping and reporting: Measles acquired in the workplace is a recordable illness on an OSHA 300 log. Like all work-related injuries and illnesses that result in an in-patient hospitalization within 24 hours of a workplace exposure, employers must report the hospitalization to OSHA within 24 hours of learning of the hospitalization.
• Personal protective equipment (PPE): OSHA’s PPE standards require that an employer must 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.
• Bloodborne pathogens (BBP): OSHA’s BBP standard applies to occupational exposure to some human body fluids, including saliva in dental procedures, which can transmit measles. The BBP standard also describes measures that could serve as a framework to control non-bloodborne exposures that can transmit measles, including exposures to body fluids (e.g., sputum, respiratory and nasal secretions and saliva, outside of dental procedures) to which the standard does not apply. When BBP applies, employers must use universal precautions, maintain a written exposure control program and provide training, PPE and engineering controls to limit or prevent exposure.
• General duty clause: OSHA’s general duty clause 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.” The general duty clause is OSHA’s “catch-all,” and employers can be cited under this standard if they fail to prevent workplace exposure of a recognized hazard. Employers should implement feasible hazard controls.

OSHA also identifies certain workplaces that increase the likelihood of worker exposure to measles, including:

• Healthcare facilities
• Laboratories
• Congregate settings (i.e. schools, daycares, detention facilities, assisted living facilities, etc.)
• High-density workplaces
• Conducting work outside of the US.
• In addition, workers who are not vaccinated or have a weakened immune system are more likely to contract measles.

State government agencies may also provide public health information about measles, including state-specific updates. For example, in December 2025, Massachusetts published an alert regarding particular exposures to measles that also provided pertinent public health information, including about vaccination. Employers can consider tasking certain personnel to track such updates.

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What should employers do? 

Preparing a plan for a potential measles outbreak for employers can help keep employees and others safe, as well as reduce legal risk.

There are a few steps to consider when managing measles exposure in the workplace.

• Notify local health departments and the CDC. If an employee contracts measles, it is important to immediately contact your local health department and the CDC. The CDC specifies to notify them of an outbreak within 24 hours by emailing measlesreport@cdc.gov. Local health departments will also likely help with contract tracing, provide resources and further guidance,
• Send the Infected employee home. Employers should also review the applicable sick time, FMLA, leave and other applicable policies to ensure compliance while employees are out of work.
• Notify exposed employees and maintain employee privacy. While it is important to notify potentially exposed employees, it is also crucial that employers maintain the privacy of the employee infected with the measles.
• Follow OSHA guidelines. If a measles outbreak triggers OSHA standards, it is important to review OSHA guidelines and adhere to them. This includes recording cases of measles that are acquired in the workplace, potentially providing PPE and other engineering controls, having BBP measures in place, if applicable, and generally providing a safe working environment for employees.

There are additional acceptable actions available to employers, including:

• Educating employees. Employers may educate employees on the measles, how to prevent infections, the MMR vaccine, symptoms and exposure. The CDC also offers resources and fliers that can be posted in the workplace.
• Voluntary vaccinations. Employers may also encourage employees voluntarily to get vaccinated. Employers can provide practical information to employees, such as where to get vaccinated and whether vaccines may be available without cost. Reimbursing for vaccinations is also likely permissible.
• Train HR. Training can be helpful; conduct training for HR and managers on what to do if a measles exposure is reported so no one is caught flat-footed.
• Consider remote work options. Where practical, consider remote work options (even on a temporary basis) for those who are quarantined after a measles exposure.

Can an employer require MMR vaccines?

Certain employers, such as healthcare organizations, have long required the MMR vaccine as a condition of employment. However, in recent years there has been increasing polarization around vaccines and, in turn, litigation around mandatory vaccination programs. 

The employer will want to weigh carefully the workplace risk associated with measles and the health and safety benefits of requiring the MMR vaccine. This may involve, for example, reviewing the particular workplace setting, any contact between employees and vulnerable populations and the vaccination rate of the workforce and community.   

Any mandatory vaccination policy should be carefully considered in consultation with counsel, to ensure that it is compliant with federal law as well as the growing number of intersecting laws that have been enacted since the start of the Covid-19 pandemic.