Enforcement and Inspection

OSHA’s 300 Log: What You May Not Know About It

The 300 Log program is the backbone of OSHA decision making, but only if the information you provide is both timely and accurate. Here are some tips to keep it so.

It’s March. That means it’s time to check out big-time college basketball, the first glimmerings of spring … and whether you’ve got your OSHA 300 Summary posted.

That’s right. We’re already more than a month past the date you should have posted your OSHA workplace injury and illness summary (Form 300A) in a common area for all (including the occasional compliance inspector) to see. By law, it had to go up on February 1 and stay up until April 30.

Remarkably, some managers we’ve talked with didn’t know all that. They thought they filled it out and they were done, or they had the posting dates wrong. So we thought it might be time for a spring-cleaning about OSHA recordkeeping basics, starting with the 300 Log itself, courtesy of BLR’s OSHA Compliance Encyclopedia on CD. This well-known and long-admired reference offers a full, plain-English analysis of all major OSHA recordkeeping rules.

If it’s OSHA and you need to know it, BLR’s OSHA Compliance Encyclopedia on CD will tell you … in plain English. See why so many depend on it. Try it at no cost or risk. Click for info.

Today, let’s look at the log. Tomorrow, we’ll review other required forms of recordkeeping, and post some tips on how to make sure it gets done.

The OSHA 300 Log (and the 300-A summary it feeds) form the building blocks of OSHA’s enforcement decision making. By tallying data from these logs through a system of random surveys sent to various businesses, OSHA builds a mosaic of injury/illness patterns by industry and locality. This gives the agency a war plan for deploying its limited inspection resources.

OSHA has been criticized for working this way. It’s been said that the 300 Log process creates a rearview mirror view of workplace safety, because last year’s patterns don’t necessarily project. However, says OSHA Compliance Encyclopedia, “whether or not you agree with OSHA that recordkeeping compliance is a good way to improve health and safety, this is the route the agency is now taking.”

Here are some ways to minimize the speed bumps along that route:

  • Know what incidents are reportable: Essentially, the injury or illness must have been incurred at the workplace or is due to workplace activity. And it must be serious, resulting in a fatality, loss of consciousness, days away from work, or a restricted work schedule.

  • Similarly, you must report any significant workplace event that leads to a health professional’s diagnosis, or medical removal from the job. Additionally, any needlestick or cut that may involve contaminated blood is reportable, as is a positive tuberculosis test after exposure to a known case of TB. In a recent addition, hearing loss on an audiometer test, outside certain parameters, is also reportable.

  • Know what’s not reportable. This category includes incidents that lead to doctor visits solely for observation or counseling, and any treatment that’s considered first aid, a category that’s fairly broad, and includes tetanus shots and even eye patches.

  • Nonprescription medications are considered first aid, but only at nonprescription strength. Larger doses, or a need for prescription medicines (except for diagnosis) make an event reportable.

  • Know how to count the days off work or on restricted work. Many employers slip up on this point: The law requires counting by calendar days (not workdays), starting the day after the incident. After 180 days, you can stop counting.

  • All the regs … all the analysis … state plan info … prescripted safety meetings. They’re all in OSHA Compliance Encyclopedia. Try it at no cost or risk. Click here.

  • Understand Employee Access. By law, workers, or their designated representatives, have broad rights to see the OSHA 300 Log. If an inspector asks for it, don’t dawdle. A copy must be in official hands within 4 business hours.

  • Adhere to the Privacy Rights. For most incidents, the name of the worker involved goes on the log. Not so for any incident involving sexual assault, intimate body parts, mental illness, or possible HIV, hepatitis, or TB infection. A worker may also request anonymity. In these situations, the entry should be “privacy case.”

  • Enter the Most Serious Outcome. Sometimes an initially nonreportable injury or illness worsens and becomes reportable. The most serious outcome must be reported.

  • Two final points: Logs must be kept a minimum of 5 years. And if you violate any of the above, OSHA won’t like it to the tune of a possible $10,000 fine and up to six months in jail … per violation. So if you haven’t done it, get that log summary posted today!