Starting on February 1, 2012 employers must use form 300A and post the annual summary of their Occupational Safety and Health Administration (OSHA) 300 logs for 2011. The posting period is from February 1 to April 30.
Who must keep OSHA records?
- Employers with more than 10 employees.
- Businesses that employ less than 10 workers or those that fall into an excepted category must also record injuries upon receiving instructions to do so from OSHA or the Department of Labor’s Bureau of Labor Statistics.
- Certain low-hazard industries are exempt.
- OSHA requires certification of 300A logs by a company executive.
Displaying Records and Accessibility
- Only the summary must be posted. The log itself does not need to be displayed, but must be available for timely inspection by employees, their representatives, or OSHA investigators. Employers are required to maintain records for 5 years plus the current year.
- Employers with multiple job sites should keep a separate log and summary for each location expected to operate for at least one year.
- Employers have 7 days after being informed of a reportable injury to record the case.
Reportable Injuries
Generally, only serious injuries that result from workplace activity are reported. If an incident results in one injury, but later develops into a more serious injury, always report the most serious outcome of the injury.
Workplace Activity
- Analyze the activity that caused the injury to determine whether it was actually due to work duties. Injuries resulting from activities merely incidental to work responsibilities do not require reporting.
Serious Injuries
- A serious injury is anything that results in a fatality, a loss of consciousness, days away from work, a restricted work schedule or job transfer, a significant injury or illness diagnosis by a health care provider, or an injury that requires medical treatment beyond basic first aid.
- Do not report incidents that only require basic first aid remedies. The OSHA instructions contain an exhaustive list of remedies that should be considered first aid.
- Employers should also consult the OSHA form 300 instructions (link above) for specific injuries that must always be reported, even if they don’t fall under the broad categories above.
Privacy Concerns
- If the injury involved is of a sensitive nature, such as sexual assault, then employers should write “privacy case” in the box for the worker’s name.
- A worker with a regular injury may also request being listed as a privacy case. Keep a separate confidential list of case numbers and names so that you can provide accurate information to the government and can update the list if a condition worsens.
