The OSHA law requires most employers with 10 or more full-time employees to keep a yearly log of all work-related injuries and illnesses.
Which employees are covered by the recordkeeping requirements?
The employer is required to record on the OSHA 300 Log the recordable injuries and illness for all employees on its payroll, including hourly, salaried, executive, part-time, seasonal, or migrant workers. The employer must also record injuries and illnesses that occur to workers who are not on the employer’s payroll if the employer supervises these workers on a day-to-day basis (including employees of temporary help services, employee leasing services, personnel supply services and contractors).
How long must the forms be kept?
Employers must save the OSHA 300 Log, the Form 300-A (annual summary), privacy case lists, and the Form 301 (or equivalent) incident report forms for five years. The stored OSHA 300 Logs must be updated by the employer to include any newly discovered recordable injuries or illnesses.
Other things to consider?
Beginning February 1 until April 30 of each year, employers are required to post their annual OSHA Summary Form 300A for the previous calendar year. This annual summary needs to be displayed in a location accessible to all employees.
Maintaining and completing a log can be challenging and confusing, so here is a list of the most common mistakes made by employers:
- Failure to maintain the Log – there are some exclusions to this recordkeeping requirement, but it is required for most companies with more than 10 employees. Not sure if you need to be maintaining an OSHA log, here is a way to help you determine here.
- Not using unique case numbers (item A) – this unique number will help keep the cases straight.
- Failure to provide a detailed description (items E and F) – OSHA requires the injury type, location and source. Putting “cut finger,” won’t satisfy this requirement. A better entry would be, “employee cut tip of left index finger while using a utility knife in the stockroom.”
- Too many columns checked for classifying the case (items G-J) – OSHA wants only the most severe information about the case. So if an employee has both days away from work and restricted days, you would only need to check the column indicated days away from work.
- Incorrect lost days count (item K) – the day of the injury is not counted as a lost time day.
- Over-counting for restricted and lost workdays (items K and L) – OSHA puts a 180-day cap for each case in each of these columns. Stop at 180 days,even if the worker has lost more time.
- Incorrect addition – double-check page totals for each column, and add the correct numbers to the 300A log. The log and summary must match at the time of the annual posting. If you choose to use the excel version of the log, the totals will transpose automatically. Note: any changes in lost or restricted days after the summary is posted must be maintained on the log, but not reported again on the summary. If questioned, any difference between the two postings can be explained.
- Incorrect certifying person – the 300A summary must be signed by the highest-ranking person at the site, not necessarily the person filling out the form
- Confusing OSHA recordable injuries with workers compensation claims – workers comp and OSHA recordkeeping are two different systems, with different definitions! If you WC insurance denies a claim, it doesn’t mean the injury can be removed from the log. And if an injury is accepted by WC as work-related, it doesn’t necessarily mean it must go on the OSHA log. Usually the two are the same, but not always! Know the difference.
- Recording every injury or illness – Know what to and what not to record. Not sure on what OSHA considers recordable? Here is a sheet to help you determine that, here.