Kevin Lindley, Safety Consultant, FRSA Self Insurers Fund
In addition to all the other administrative burdens, there is also the requirement by OSHA to update, verify, log and post the OSHA 300 log and 300A form. The OSHA 300 form must be posted in a visible location at the place of business from February 1 through August 30. It is recommended that individual employee names be removed from the copies posted in the facility. A
digital copy of the OSHA 300 log, 300A form and the OSHA 301 form are available on OSHA’s website at
www.osha.gov/recordkeeping/forms.
Let’s start with a description of what the OSHA 301 form, 300 log and 300A form are.
The OSHA 301 form is an Incident Report document for job-related injuries and illnesses. This form helps you record what happened at the time of an injury or accident and will be beneficial when it comes time to enter the information into your 300 log.
The OSHA 300 log is a record keeping document used throughout the year to list and track any recordable injury which occurs at work to an employee throughout the calendar year. Information about the individual involved in the incident, date of incident, location, classification of the injury/illness, type of injury/ illness as well as total number of days, both away from work and return to work, on light duty or transfer are to be entered on the log.
The OSHA 300A form is the Summary of Work-Related Injuries and Illnesses. It must first be determined if an injury or illness that occurred at work is a “recordable injury.” NOT ALL INJURIES ARE. An injury or illness meets the general recording criteria as a recordable injury if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid or loss of consciousness. A case must also be taken into consideration for the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid or loss of consciousness. There are many basic requirements used to determine if an injury is a recordable injury, too many to list in one article. For a complete list of basic requirements go to www.floridaroof.com/osha-1904-7. Classes are also available online for a complete understanding of OSHA recordkeeping requirements that employers may attend or research.
A common mistake on the OSHA 300 log is to enter the number of days in the incorrect column. The only location the actual number of days is entered on the OSHA 300 log is column K or column L. All other columns for classification and type of injury/illness are a check mark. Once the information for each injury/illness is entered onto the OSHA 300 log, the final row at the bottom of the page is totaled for all categories, types and days away from work and job transfer/restricted workdays. If the company is requested to share information from the OSHA 300 log, it is recommended that all individuals names and personal
information be removed from view on the log prior to sharing.
Once the OSHA 300 log is complete, the OSHA 300A form can be correctly entered. The OSHA 300 log totals entered at the base of the page are then referenced and entered into the first half of the OSHA 300A form. Additional information is required about the company, number of employees, total time worked by all employees, as well as a general description of work and a signature by a company executive. For companies who are required to electronically submit their OSHA 300A Summary form online, it is
recommended that two individuals within the company have the profile information and log-in code once the establishment information has been created within OSHA’s Injury Tracking Application (ITA), www.osha.gov/injuryreporting/ita.
There are also injuries/illnesses that are not only “recordable” but also “reportable.” All fatalities, hospitalizations, amputations and loss of an eye as a result of work-related incidents are REQUIRED to be reported to OSHA either over the phone or through their
website within a stated period of time. You must report the fatality to OSHA within eight hours after the death of any employee as a result of a work-related incident. Within 24 hours after any in-patient hospitalization, amputation or loss of an eye as a result of a work-related incident, you must report the case to OSHA.
Companies with ten or more employees are required to keep a record of work-related injuries and illnesses on the OSHA 300 log and 300A form for a minimum of three years. Those companies with a peak employment of twenty or more employees are also
required to submit their OSHA 300A form to OSHA on an annual basis using the injury tracking application (ITA) online. Just a reminder; 2021’s OSHA 300A form is due prior to March 2, 2022. All employers, regardless of number of employees, must follow the OSHA reporting requirements listed above.
OSHA has expectations and requirements for employers. The OSHA 300 forms play a vital step in the process of an OSHA investigation as well as providing statistical data to OSHA for guidance on indicators where more training and attention is needed. The OSHA recordkeeping and reporting process has not changed since August 2017, when they implemented the electronically submitted injury tracking application. The number of employers who are still unaware of their requirements is alarming. Employers must not only submit the information online but also maintain their OSHA logs and forms. Now is the perfect time to
begin the logs and forms if you are not already completing them. They may never be needed; however, if they are ever requested, attempting to complete them at a later date is always more difficult and could prove very costly.
For additional details on any claims that your company may have had, you should contact your workers’ compensation insurance carrier or agent to request your loss runs. However, workers’ compensation reports are not a complete record of injuries required
to be entered on the company OSHA 300 log because many injuries are not reported and days of light duty are not tracked. It is best that the OSHA 300 log be maintained and updated regularly throughout the calendar year by a designated company employee. Remember, those 2021 OSHA 300A forms are due to be electronically submitted to OSHA on or prior to March 2, 2022.
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