It is that time of year again: time to post your company’s Occupational Safety and Health Administration (OSHA) form 300A Summary of Work-Related Injuries and Illnesses 300 log. Each year, employers with 11 or more employees must post a summary of the previous calendar year’s injuries and illnesses. This posting helps keep employees informed about the hazards in their workplace.
Because the topic is complex, I will give only a brief overview of the requirement. If you need more details, the OSHA Web site shown below is very informative. If you have questions after reading OSHA’s instructions, you can call the consultation side of your local OSHA agency. At this time of year, they field many reporting-related calls. A call to OSHA consultation does not generate an inspection, so never hesitate to call OSHA.
Not all businesses must complete the OSHA log. A list of the exempt businesses is available at this link. Meat markets, hardware stores, most retail stores, insurance agents, and bowling centers are a few of the businesses not required to report.
To complete the OSHA 300 log, which contains the details of the 300A Summary of Work-Related Injuries and Illnesses, employers must classify work-related injuries or illnesses, noting:
- The severity of the injury.
- How the incident occurred.
- How many days the employee lost from work or worked restricted or temporary modified duty due to the injury.
You must update the OSHA 300 log within seven days after each injury or illness. If an OSHA official inspects your facility, he or she normally requests this log. Therefore, it is important that you keep it up to date. One of the biggest failing of smaller employers is to procrastinate, waiting until the end of the year to complete the log. As your organization grows, it may be a good idea to invest in one of the many OSHA log reporting software tools on the market.
Not every on-the-job incident is “recordable” for OSHA recordkeeping purposes. For example, the employee may receive only first-aid treatment or the incident may be an exacerbation of an earlier injury already reported. The U.S. Department of Labor provides many on-line resources regarding the log and how to complete it at this link: http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf
If your company location has fewer than 11 employees, OSHA may still require your organization to complete the OSHA 300 log and summary if your total organization has more than 11 employees — since the requirement applies to the entire employer.
In addition to completing the report, post the Summary at each of your locations. So if you operate in both Los Angeles and San Diego, for example, a separate log may be necessary, but minimally the summary must be posted at both sites. Post the Summary from February 1 to April 30 each year in a visible place, for example a lunchroom. A company executive must certify the Summary, although your workers’ compensation coordinator is generally best suited to complete it prior to certification because your company must record several pieces of information, including the number of lost or duty-transferred days.
To protect an employee’s medical information in cases involving injuries to “intimate body parts,” involving a sexual assault, mental illness, needlesticks, or when the employee requests his or her name not be shared, list these incidents as a “privacy case” on the log. However, you must keep a separate file on each privacy case. Remember, place names on the OSHA 300 log, not the Summary, and post only the Summary.
The OSHA 300 log and the posting of the OSHA 300A Summary is a complex process. After they are completed, do not send the forms to OSHA unless they specifically request them. However, any inspection will no doubt include a review of the forms.