Time to finalize your OSHA 300 logs

It’s OSHA 300 time again, so 70 Approach clients joined us online this week for our annual OSHA 300 Brain Trust. Here’s a look at what we covered and how your company can prepare your logs for posting and submission.

What are the OSHA 300 and 301 logs?

The OSHA 300, 300A, and 301 forms all work together to form your OSHA 300 log.

• OSHA 300 is the form that you keep throughout the year, with basic information about your company and a summary of any recordable incidents that have occurred so far that year.
• OSHA 301 is the form that you must complete within 7 days of a recordable incident.
• OSHA 300A is annual summary that must be posted February – April of the following year.

OSHA uses these logs to determine safety trends and accident rates. They are focused on serious injuries as defined by OSHA. “I say it every year, but OSHA 300 recordable incidents are not the same as L&I claims” says Amy Davidson, Approach Safety Manager.

Note:

It’s very possible to have an L&I claim that does not result in an OSHA 300 recordable incident.

It’s also possible (but unlikely) that you’d have an OSHA 300 recordable incident that doesn’t result in an L&I claim.

Are OSHA 300 forms required in Washington state?

If your company had 10 or more employees in 2021, you are required to keep and submit these logs. This is true even though workplace safety in Washington state is regulated by the state Department of Safety and Health (DOSH). If you’re counting employees to see if the OSHA 300 log is required, you should include:

• All employees on payroll
• All employees you supervise on a day-to-day basis (including temporary workers).

“If you are a smaller company and vary between 10 or 11 employees during the year, I would keep a log just in case,” says Amy.

Does my company need to keep an OSHA log?

You keep an OSHA Log if:

1. Your company had 11 or more employees at any time during the year (peak employment), and
2. Your establishments are not in low-hazard industries (listed in Table 1).
3. Regardless of above, you always keep OSHA logs if DOSH/OSHA/BLS inform you to do so in writing.

You keep multiple OSHA Logs if:

1. Your company must keep an OHSA log, and your company had multiple establishments, and at least one establishment was expected to be in operation for one year or longer – EACH establishment would get their own OSHA Log, and short term establishments can be merged into a single OSHA log
2. Your company had multiple establishments, but your company did not meet the 10 person / yearlong requirement – you keep ONE log for the WHOLE company

Learn more by reading the WAC – Electronic submission of injury and illness records to OSHA.

“If you are a smaller company and vary between 10 or 11 employees during the year, I would keep a log just in case”

Fill in your OSHA 300 logs promptly

Really, the whole year is OSHA 300 time, because it’s a requirement that recordable incidents are entered into onto your OSHA 300 AND 301 within 7 days. Your company could be cited if you’re inspected mid-year and an incident is missing, so don’t wait until January to update your logs all at once.

Posting and submitting OSHA 300 logs

Once the year ends, you can use January in order to verify your 300 and 301 forms, so that the 300A can be completed accurately.

Once complete, the 300A for the prior calendar year must be:

• Signed by a company executive or owner
• Posted in a visible place at the work location for all of February, March, and April
• Submitted to OSHA by March 2. Many companies, including those in Construction, Transportation, and Manufacturing, must submit their logs electronically.

Electronic filing for OSHA 300

Electronically submit an Injury Tracking Application (ITA) if:

• Your company keeps at least one OSHA log, and at least one establishment had 250 or more employees, or
• Your company keeps at least one OSHA log, and at least one establishment had 20-249 employees during the course of the year (not peak employment – instead looking at rolling/cumulative total of individual people) and the establishment’s NAICS code matches those listed in Appendix B (high-hazard industries).

NOTE: Construction, manufacturing, and transportation companies are considered high-hazard industries.

• Regardless of above, you always electronically report OSHA logs if DOSH/OSHA inform you to do so in writing.

It’s a requirement that recordable incidents are entered into onto your OSHA 300 AND 301 within 7 days, so don’t wait until January!

Common questions about OSHA 300

Below are some of the questions Amy frequently answers. You can also see our OSHA 300 FAQs from 2019 and our OSHA 300 update from 2020 for more tips and answers.

When counting days of restricted work, what is a “routine job function?”

A routine job function is something done by the employee at least once per week. If they’re not able to carry out this duty because of the injury, then the day should be counted as one of those with restricted work.

We’re not open on weekends. Do I need to count those days?

Yes, OSHA requires all calendar days, except for the date of injury, to be counted. “It’s frustrating to count all days, but OHSA wants to know how many days that employee missed being available for work, regardless of if any work was scheduled,” says Amy.

Will we be cited for something entered on our OSHA 300?

As of now, there’s no enforcement via DOSH of anything you report on your OSHA 300. However, remember that all serious injuries, including the loss of an extremity or eye, must be reported to DOSH within 8 hours.

I got a letter the Bureau of Labor and Statistics. What do I do?

The BLS research is a separate project. If you get letter from Bureau of Labor and Statistics, you must do that as well as the OSHA electronic reporting.

What counts as an establishment?

A single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc., that either supervise such activities or are the base from which personnel carry out these activities.