If you are required to maintain an OSHA 300 log of recordable injuries and illnesses, you must post the 300 A Summary sheet by February 1, 2015. It should be posted in an area where your employees will be able to see it. You must keep it posted until April 30, 2015. Be sure to post only the 300 A form and not the 300 log itself.
The only companies that are not required to use the OSHA 300 log are those with ten or fewer employees at all times throughout the year. This is not a full time equivalent number and even a part-time employee counts as one employee. The other exemption is for those companies that are in low hazards industries as determined by OSHA. For the list of low hazard industries check out this link. OSHA added new industries to the recordkeeping requirement at the end of last year. These companies will be required to record injuries on the log starting this year. Here is a link to that list.
If you are not exempt, you must record work-related injuries and illnesses. OSHA developed an excel workbook that contains all of the forms needed to fulfill this requirement. The link to the workbook is found here. Not all work-related injuries and illnesses must be recorded and OSHA has a guide at the record-keeping page on the www.osha.gov website.
The first thing OSHA will usually ask to see when they arrive for an inspection are the OSHA logs. Be sure to keep five years plus the current year on file. If the logs show that there have been low rates of injuries, especially those that result in lost work time or other restrictions, OSHA will often leave and will not conduct an inspection. The logs must be accurate and complete.
Another change OSHA made towards the end of 2014 regards the requirements to report injuries to OSHA. Here is the updated requirement. All work-related fatalities must be reported to OSHA within 8 hours of finding out about it. All inpatient hospitalizations, amputations or injuries involving loss of an eye must be reported by the employer within 24 hours of learning about it. OSHA’s reasoning behind this change was to capture information about the more serious injuries that take place at work and to be able to respond and investigate those injuries.
Two significant changes at the start of a new year. Please let us know if we can help with any questions or resources you may need.
Rich Galutia CSP specializes in the areas of employee safety (OSHA), trucking compliance (FMCSA) and animal feed safety (FDA).