By now most companies are aware as to whether or not they are required to maintain a record of OSHA recordable injuries and illnesses on the from know as the OSHA 300 Log. Unless a company has less than 11 employees (full and part-time) or are in a low hazard industry, it is required to maintain this record. Here is a link to the low hazard or partially exempt industries. https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html
This time of the year, companies receive reminders from various sources that they must post their 300 A Summary form for 2013 by February 1. Hopefully, your company had no injuries or illnesses during the year and will be able to zero out all of the columns on the log and summary. Although there is essentially nothing to show, you are still required to complete the log and post the 300 A in a place where all of your employees can see it.
If you had one or more recordable injuries, hopefully you logged it within the 7 day requirement. If not, please make sure you log all of your injuries and illnesses for the past year. It is never too late to fulfill this requirement, even if it you need to go back a few years to complete a log. Do not back date the log! Use the date you complete it.
Here is a link to the OSHA site where you can obtain forms and an excel spreadsheet with all of the available forms. The spreadsheet will automatically fill in the 300 A form as you complete the log.
The following are some common questions and answers regarding log completion and posting.
How do I calculate the “total hours worked” on my annual summary when I have both hourly and temporary workers?
To calculate the total hours worked by all employees, include the hours worked by salaried, hourly, part-time and seasonal workers, as well as hours worked by other workers you supervise (e.g., workers supplied by a temporary help service). Do not include vacation, sick leave, holidays, or any other non-work time even if employees were paid for it. If your establishment keeps records of only the hours paid or if you have employees who are not paid by the hour, you must estimate the hours that the employees actually worked.
How would the employer record the change on the OSHA 300 Log for an injury or illness after the injured worker reached the cap of 180 days for restricted work and then was assigned to “days away from work”?
The employer must check the box that reflects the most severe outcome associated with a given injury or illness. The severity of any case decreases on the log from column G (Death) to column J (Other recordable case). Since days away from work is a more severe outcome than restricted work the employer is required to remove the check initially placed in the box for job transfer or restriction and enter a check in the box for days away from work (column H). Employers are allowed to cap the number of days away and/or restricted work/job transfer when a case involves 180 calendar days. For purposes of recordability, the employer would enter 180 days in the “Job transfer or restriction” column and may also enter 1 day in the “Days away from work” column to prevent confusion or computer related problems.
If a case occurs in one year but results in days away during the next calendar year, do I record the case in both years?
No, you only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.
How do I certify the annual summary?
A company executive must certify that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.
A company executive for certification purposes is either: 1) the owner; 2) an officer of the corporation; 3) The highest ranking company official working at the establishment; or 4) The immediate supervisor of the highest ranking company official working at the establishment.
Remember that the all of the forms must be retained for five years and updated during that time as needed. Your company’s OSHA Log and Summary form will most likely be the first documentation an OSHA inspector asks to see at the start of an inspection.
To gain an understanding of the basics of recordkeeping, a good source is the tutorial on the OSHA website found at this link. Https://www.osha.gov/recordkeeping/tutorial/player.html
Rich Galutia CSP specializes in the areas of employee safety (OSHA), trucking compliance (FMCSA) and animal feed safety (FDA).