• Why does OSHA require an OSHA 300 log?​

o    OSHA’s primary goal is to protect employees across the United States from being injured on the job.  Those protective measures come in the form of hundreds of regulations.  One requirement of OSHA is to report certain injuries and illnesses on an annual report called the OSHA 300 Log of Injuries and Illnesses.  These are the injuries that are considered “recordable.”  In addition, OSHA must be contacted directly when a more serious injury or fatality occurs.

Why does OSHA require recording injuries on an OSHA 300 Log you might ask?  It often seems confusing as to why OSHA requires the OSHA 300 Log to be completed, when the Agency does not require that it be submitted in most circumstances.  OSHA requires the log to be maintained as a resource or tool for employers to use.  They can use the log to capture any trends in injuries or illnesses that are occurring at a workplace and compare their company statistics to national industry averages.  According to OSHA, “employers and employees use the records to implement safety and health programs at individual workplaces.  Analysis of the data is a widely recognized method for discovering workplace safety and health problems and tracking progress in solving those problems.”  In addition, some companies will require their clients and/or customers to maintain an injury rate below the national average for the industry, which the OSHA log will help to determine.

• What is an OSHA 300, 300A and 301 Log?
  • OSHA 300 Log: “The Log of Work-Related Injuries and Illnesses”
    • Used to document the details and classify work related injuries and illnesses and extent and severity of each incident/case.
    • This log is NOT to be posted, because it may contain confidential employee information.
  • OSHA 300A: “Summary of Work-Related Injuries and Illnesses”
    • Summarizes injuries and illnesses that occur each calendar year.
    • Includes calculation of TRIR and DART scores:
      • TRIR: Total Recordable Incident Rate
      • DART: Days away from work, restricted work activity and job transfer.
    • Must be posted each year from February 1st through April 30th (at each company location).
  • OSHA 301: “Injury and Illness Incident Report”
    • Used to detail each recordable incident.
    • Must be completed within 7 calendar days of the incident.
• Which injuries and illnesses need to be recorded on the log?
  • Only “Recordable” injuries and illnesses need to be recorded.
    • All fatalities
    • All injuries and illnesses resulting in days away from work.
    • All injuries and illnesses resulting in job transfers or restrictions.
    • Medical treatment beyond first aid (ie: stitches, prescription medication, etc.)
    • Loss of consciousness

Some quick tips, based on observations Berg consultants have seen in the past.

• OSHA 300 has multiple injury type blocks checked.  Only one block is checked, and it is the worst case.  If an injury started as a Restricted/Job Transfer case and then the employee lost time, it would be treated as a lost time, and only that block is checked.
• Days away or Restriction/job transfer numbers have not been updated.  The information on the 300 log should be updated whenever you receive a new Dr note to reflect the new changes.  This may mean going back to the previous year OSHA 300.
• Information on the 300A doesn’t match the 300.  If your 300 is accurate, then transcribing the totals from the 300 to the 300A should be easy.  Normally we see inaccurate 300 data then transferred to the 300A.  With the new electronic reporting, we will want to ensure accurate date.
• Establishment information missing.  Key information we often find missing is the establishment’s SIC or NAICS code not entered.  These codes, Standard Industrial Code or the North American Industrial Code System are important, not only to determine if you fall under the electronic recordkeeping requirement and OSHA Emphasis areas, but may also impact your environmental compliance.  We have seen where companies have mis-identified their SIC or NAICS.  Mis-identification can also impact your environmental requirements.
• Hours worked is missing.  This would include all hours all your employees, including temps (as referenced above.  Do not include sick or vacation, but include work related travel and work from home hours.
• Average number of employees date is missing.  Take the number of employees, including temporary employees, you had each month.  Add those results from each month together and dive by 12.
• Have a company executive sign and date the form.  This is normally a company executive, but if you have multiple facilities, the senior person on-site can sign the form.
• Post by February 1 in areas where employees read bulletins or company announcements.  This may be in multiple locations throughout your facility.
• Remember, you must maintain 5 years of OSHA 300, 300A and 301 forms.  OSHA will request these documents on any visit they perform.

As a reminder, if you fall under OSHA’s requirement for electronic reporting, the information must be submitted through the OSHA Portal by March 2, every year.

This information is only meant to offer basic information regarding these forms, but there are many more details and requirements that apply to each form. Learn more below