Friday, January 13, 2012

OSHA Recordkeeping: What do I do with this 300 Log?

Well, a new year is upon us (at least if you follow the Gregorian calendar) and since the bustle of the winter holidays is mostly past, it’s probably time to start thinking about your required OSHA recordkeeping duties, if you haven’t done it already.

One of the many elements of worker safety that the OSH Act established is a requirement for employers with more than ten employees to keep records of employee work-related injuries and illnesses. There are some exempted industries (mostly retail and service occupations), and they can be found on the OSHA website. This recording system is most commonly known by the name of the form itself – the OSHA 300 Log.

Ideally, employers will keep track of the 300 Log throughout the year; adding log entries within the specified seven days required by OSHA, but even if you let it slip, it is not too late to get started. Firstly you must determine whether or not an injury or illness is recordable. In general, it’s pretty safe to say that if an injury or illness requires more than first aid to treat, then it must be recorded. If an employee loses consciousness, has restricted or light duty, or misses days from work, it must also be recorded. There are some exceptions and clarification to this, and they can be found in the applicable OSHA standard, or you might wish to enlist the help of a safety consultant to assist in the process.
After injuries or illnesses are reported by employees, the employer must make a record of the incident with certain pertinent details. The ‘OSHA 301: Injury and Illness Incident Report,’ may be used for this purpose, but employers may use alternate forms, (often provided by insurance carriers, or the like) as long as they contain the same information. Incident Report forms should be completed as soon as practical after the report of an injury or illness, so relevant details are not forgotten or omitted.

The next step is to simply fill out the OSHA 300 Log form. It is a pretty self-explanatory form that will require, among other things that you enter the injured employee’s name, job title, date of injury, location of injury, and description of the injury. Then, if the employee lost time or had restricted duty days (or both) you add up the number of days and record it in the appropriate blanks on the form. Even if the company had no work-related injuries, there is still a requirement to keep a log for that year. This form is then kept on record, for at least five calendar years. Incidentally, the forms may be maintained electronically, and is available as an Excel or .PDF file here.

The part of the process that is especially important at this time of year is to fill out the Summary Log, or 300A Log, for the previous year, so it can be posted for employees to view. (The 300 Log is never posted, as it contains personal medical information.) This is one of the employer duties under the OSH Act, and employers may be cited for failing to post the relevant information. It is required to be posted in a conspicuous place between February 1st and April 30th. The 300A Log just lists the total number of injuries and illnesses, and the total number of days away from work, and the total number of restricted duty days. A company officer (or the highest-ranking manager at a location) must then sign the form to validate it before it gets posted.

Remember, January 1st starts a new year for workplace injuries and illnesses, so if your company had a great year last year, keep up the good work! Remember, though, even if there were no reportable injuries or illnesses, the 300 and 300A Logs must still be maintained and posted as required. They will just contain a bunch of zeroes! If there is some room for improvement, then get the training and information you need to resolve to make this year better. Numerous resources exist to get companies the information they need to keep employees safe at work, and decrease costs related to injuries and illnesses on the jobsite, so get the help you need to make 2012 the safest year in your company's history.


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