So you know that you are supposed to keep an OSHA log (300 form) and you know that you are supposed to document work-related injuries, but did you know that entering too much information can “hurt” you?
Each year thousands of questions come in asking for clarification on what should be on the log and what should NOT be written on the log.
Here are answers to the top 3 questions you might have about recordkeeping and OSHA Compliance
1) What happens at the end of the year if my employee is still seeking medical treatment? Do I have to document on both logs?
No. The OSHA 300 log is considered an annual tracking system. This means that each log is used to document injuries that occurred during that year. If your employee was injured on 12/31/2015, then all tracking stays on the 2015 300 log and does not go on the 2016 log even if they are seeing a doctor for many months into 2016.
2) What should I do if an employee was terminated or quit during the year? Do I still have to track their treatment on the 300?
Yes. There are several letters of interpretation that help clarify this question (it’s a common one!). In November 2006, OSHA released an interpration letter making it clear that you should update your 300 logs as you receive information through the 5 year retention period. In addition to this section, another interpretation letter issued in 2008 indicates that in these circumstances, “you must estimate the total number of days away or days of restriction/job transfer and enter the day count on the 300 Log.“ Do remember though, that if you are still receiving information such as changes in diagnosis or final days of time loss, then you must update the log.
3) We report incident only and first aid cases to our insurance company do we record those on the OSHA 300 log too?
No. OSHA only requires cases to be recorded if they meet certain criteria. If an employee does not seek treatment from a healthcare provider, then do not record them on the log. Further, if the employee DOES go to the doctor, but only receives “First-aid” treatment and is then released, it is also not recordable due to the treatment (it might meet other criteria). For a complete list of the treatments that OSHA considers FIRST AID and are NOT recordable, we refer directly to 1904.7(b)(5)(i) and 1907.7(b)(5)(ii). There are also a few standard interpretations that clarify a few of the First Aid treatments so either check with a credible consulting firm or review these prior to recording.
The OSHA 300 log was designed to create a snapshot of what’s going on within your company and simplify the way you track trends and ultimately prevent injuries. OSHA collects this data through the Bureau of Labor and Statistics (BLS) and uses it to first identify problem areas and then second to understand what is going on with you. Your most important task with the 300 log is to record injuries accurately. Over-recording can open the door immediately to an inspection and under-recording naturally looks like you are hiding something which can also lead to penalties and citations. You can avoid both problems with a little due diligence and a partnership with the OSHA Connection.