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Background. Under OSHA’s injury and illness recordkeeping requirements, employers must record a work-related injury or illness if it meets one or more of the general recording criteria. It must be recorded if it results in one or more of the following:
- Death
- Days away from work
- Restricted work
- Transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- Diagnosis by a physician or healthcare professional of a significant injury or illness
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These scenarios were presented over the course of 2015 to BLR® safety experts.
On a multiemployer jobsite under the direction and control of a primary controlling contractor (C), one of the subcontracted employees (A) was struck by a vehicle and injured by another subcontractor (B). Whose OSHA log is the injury recorded to? The subcontractor (B) who injured the employee? The subcontractor (A) who pays the injured employee’s payroll? Or, the controlling contractor (C)?
The general rule of thumb is that the employer that is supervising the employee at the work location records the injury regardless of which employer is paying the employee. If the controlling contractor supervises the employee of Subcontractor A on a day-to-day basis, the controlling contractor must record the injury or illness. If the subcontractor’s employee is under the day-to-day supervision of the subcontractor, the subcontractor is responsible for recording the injury or illness. The controlling contractor and subcontractor should coordinate their efforts to make sure that each injury and illness is recorded only once.
Is the following a recordable incident? Individual was stung by a bee during a company picnic that was held on company property; individual used an EpiPen® due to allergic reaction.
Yes, a bee sting is recordable. A bee sting at work that requires prescription medication to treat an allergic reaction to the sting is recordable as an injury if the allergic reaction to the sting is instantaneous, and is recordable as an illness if the allergic reaction occurs hours or more (noninstantaneous) after the sting.
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If we have a temporary employee who is injured and put on restrictions, do we keep up with those restrictions if the employee is placed at another job not with our company?
If the placement at another job is unrelated to the injury, you stop counting restricted days on the date the temporary employee began working at the new workplace. If the temporary employee was placed at another job because of the injury, you must estimate the total number of days away or days of restriction, and enter the day count on the OSHA 300 Log.
We have a site with 25 people and a site with 4 people. While we keep an OSHA 300 Log for the 25-person site, do we need to keep a log for the 4-person site? Can we keep it at corporate in another state and city?
Under 29 CFR 1904.30(a), you must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for 1 year or longer.
Yes, you may keep the records for an establishment at your headquarters or other central location if you can:
- Transmit information about the injuries and illnesses from the establishment to the central location within 7 calendar days of receiving information that a recordable injury or illness has occurred; and
- Produce and send the records from the central location to the establishment within the time frames required by 29 CFR 1904.35 and 29 CFR 1904.40 when you are required to provide records to a government representative, employees, former employees, or employee representatives.
Comments “Is the following a recordable incident? Individual was stung by a bee during a company picnic that was held on company property; individual used an EpiPen® due to allergic reaction.” If the picnic is a voluntary recreational activity then the bee sting would not be work-related regardless of the location and therefore not recordable.