Finally 2020 is over! As a new year begins, we have one final close out item from the previous year, our OSHA 300 Logs. This blog will assist in finalizing your 2020 OSHA Logs, remind you about recordkeeping and reporting requirements, and prepare you for the 2021 work year.
What is a Recordable injury
The basic requirement from the General Recording Criteria 29 CFR 1904.7 standard states “You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following:”
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness or
- A significant injury or illness diagnosed by a physician or other licensed health care professional
- New for 2020 - Confirmed work-related COVID-19 cases are considered an OSHA recordable event
If an injury or illness is deemed recordable, you must fill out the required corresponding OSHA form, entering all required information. If you are unfamiliar with the required recordkeeping forms, please visit OSHA’s website .
- Form 300 - Used to classify work-related injuries and illnesses and to note the extent and severity of each case.
- Form 300A - Shows the totals for the year in each category. At the end of the year, post the Summary in a visible location so that your employees are aware of the injuries and illnesses occurring in their workplace.
- Form 301 - Provides the details of the injury and injured workers personal information. This can be substituted by your insurance companies First Report of Injury form if the form covers the same information that is found in the 301 Form.
Multiple Establishments - Many organizations have multiple jobsites, facilities, or locations and need to take certain measures to properly follow the standard. OSHA requires that you must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer. For more information, read OSHA’s FAQs.
Online Reporting – On Aug. 1, 2017, the Injury Tracking Application (ITA) was launched by OSHA. This was created for employers to electronically submit required injury and illness data. Not every company is required to participate, but those “Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. A list of industries can be found on OSHA’s website here.
OSHA only requires the OSHA 300A to be submitted and the deadline will be March 2 of each year. If you fit the criteria for online reporting and have not created an account online, you can do so here.
Posting – 300A Form must be posted each February through April, in a conspicuous area for employees to observe.
Severe Injury Reporting – Employers are required to notify OSHA of any worker fatality within eight hours. Amputations, loss of an eye, or hospitalization of a worker must be reported within 24 hours.
Most Common Mistakes
- Failure to retain OSHA Logs for five years.
- Failure to properly certify OSHA Logs. A company executive must review the information provided on the OSHA 300 Form and verify that it is accurate and complete.
- Failure to post the OSHA 300A Form. You must post your prior year's OSHA Form 300A, the annual summary, in a conspicuous area from February 1 until April 30 of each year.
- Not recording in a timely manner. You must enter each recordable injury or illness on the OSHA 300 Log within seven (7) calendar days of receiving information of the recordable injury or illness.
NEW for 2020 Covid-19 Related Topics – According to OSHA’s memorandum on COVID-19, COVID illnesses are considered a recordable event if specific criteria is met. Those criteria are outlined here.
There are still many questions regarding the use of PPE as it relates to COVID-19. Please see the following links on respirator use in the workplace in the COVID environment.
- https://www.assp.org/news-and-articles/2020/11/11/osha-issues-guidance-on-covid-19-related-inspections utm_source=MagnetMailfirstname.lastname@example.org&utm_content=ST%20%2D%20Standard%20Update%2011%2D20%2D20&utm_campaign=standards
For specific questions or assistance with recordkeeping requirements, please contact your local Marsh & McLennan Agency representative.