The Occupational Safety and Health Act of 1970 (OSH Act) requires covered employers to prepare and maintain records of occupational injuries and illnesses. Are you a covered employer? Do you know what is required on an OSHA 300 log? We will answer some basic questions you might have about your OSHA compliance and how to easily maintain an OSHA 300 log.

Are you a covered employer? What is a partial exemption?

If your company had ten (10) or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the BLS informs you in writing that you must keep records. These usually come in the form of a notice from the BLS in the mail. Even though you might not have to keep an OSHA log by your size standard, employers covered by the OSH Act must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees federally, and one or more employees in our state of Utah. It’s wise to know if your state operates under the Federal OSHA program or your own state program. If your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry (which can be found under Section 1904.2). The partial exemption for size is based on the number of employees in the entire company. The easiest way to determine the size is to calculate the number of employees during your peak employment for the calendar year. If you had no more than 10 employees at any time in the last calendar year, your company qualifies for the partial exemption for size.

The other partial exemption could be the industry type that you operate in. There is a list of exemptions on the www.osha.gov website that can help you decide if you’re in that grouping. OSHA has stated that “business establishments classified in agriculture; mining; construction; manufacturing; transportation; communication; electric, gas and sanitary services; or wholesale trade are not eligible for the partial industry classification exemption.”

If you are required to maintain records of injuries, OSHA has stated that each employer is required to keep records of injuries, illnesses and fatalities that are work-related and must keep records of each new case. Although OSHA requires injuries to be recorded, it doesn’t necessarily mean that they will need to be recorded on the company’s OSHA 300 log. The OSHA website has general recording criteria that provides information on whether an injury needs to be placed on the OSHA 300 log or not. The recording criteria can be somewhat confusing and hard to decipher – the best way to understand it is to read the criteria itself from the OSHA website.

A simple way to maintain these records is to keep a current running OSHA log for your company at all times. Waiting until the end of the year to update or create an OSHA log can be confusing, time consuming, and inaccurate. On the www.osha.gov website, they offer a Excel and PDF version of the OSHA log to save right to your own computer. You can update and edit these logs as your employees get injured, heal, and eventually be released from care. At the end of the year, or at the close of a new case, you can always delete an entry that might not be required on the log. Some examples of injuries that (most likely) do not need to be recorded on the 300 log are: basic first aid cases with no prescriptions given or follow up care needed; a precautionary x-ray with a full release; or a basic eye wash with no other symptoms or treatments. Each of these examples could be excluded from the OSHA 300 log (pending no other treatments or medications given). As an HR professional, I keep a running OSHA log and delete cases as they are closed and not needed on the log, and continually update other cases in which employees are still working on restricted or modified duty. It keeps things simple, organized, and accurate at all times. Keeping track of medications prescribed, the number of days away from work or on restricted duty, and the dates of the injuries are three major components of determining and accurately recording injuries.

Once your log is complete (which would be December 31st), you will need to post the 300A in an area of your business where all employees can view the log. This log must be posted from February 1 – April 30th each year. You have 31 days during the month of January to review your cases, determine specifics, and make sure it’s accurate.

Some local insurance agencies may offer classes on understanding the OSHA log or might be able to answer questions about the OSHA 300 log. Good worker’s compensation insurance companies may also help you determine what cases are recordable or not. Work with your adjusters to make sure you don’t miss a case that should be recorded. If you still have questions, I recommend calling an OSHA consult line. The OSHA consult employees are always eager to answer questions or direct you to the correct information you might be searching for. You can always use a PEO like Solution Services as well – not only do we manage all your Worker’s Compensation claims; we create, manage, and post the OSHA log on your behalf.