It’s time to close the OSHA Recordkeeping books for 2019. The deadlines are February 1st and March 1st 2020.
If you had more than 10 employees at anytime during the year, you are required to maintain an OSHA 300 Log and post a 300A for 2019. This includes temporary employees that you directly supervised and controlled. If you have multiple facilities, each facility would be considered an Establishment and requires it’s own 300 & 300A.
- Ensure your work-related injuries are documented on the OSHA 301 Incident Report form. You can use an equivalent form as long as it, at a minimum, contains the same information as the 301. A First Report of Injury form you receive from your Workers Compensation carrier would suffice.
- Ensure you injury logs us up to date and current. OSHA recommends using the OSHA 300 Log of Work-related Injury and Illness form. You can use your own form, if it contains the same information as the OSHA 300 and in a similar to read format. The information in this log is derived from the 301 or your injury reporting forms.
- Prepare your OSHA 300A (or equivalent state form) using the information from your OSHA 300 log. The form should be certified by a company executive and posted in areas where employees gather (announcement boards, breakrooms, etc) by February 1. You may remove the form starting May 1.
- DO NOT post your OSHA 300 form, only the 300A. Your 300 will contain employee names, which are considered protected information.
- A reminder that if you fall under OSHA’s requirement for electronic reporting, the information must be submitted through the OSHA Portal by March 1, 2020
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.
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