OSHA Recordkeeping Done Right!

One of the benefits of being a safety consultant at Ohio’s Electric Cooperatives is that I get to evaluate a lot of different cooperatives’ OSHA Logs. Through the years,  I have seen the same mistakes many times. When I find errors in OSHA logs, I know I need to do better or more frequent training on the subject. 
I would like to share some of the most common errors that I have found through the years on OSHA logs with the hope that you will be able to avoid the same mistake, and possibly, an OSHA citation.

  • No case number appears on Form 300 and Form 301. The case number must be placed in column A on Form 300. This same case number must also be included on Line 10 of Form 301 or its equivalent. Whatever form you use as the first report of injury must also have the case number on it somewhere.
  • Check marks entered in both column H and column I. Column H is for days away from work and column I is for job restriction of transfer. If an employee is off of work for a few days and then comes back under restricted duty, you place a check in the column indicating the most severe outcome. In this case, it would be days away or column H. 
  • Not entering both the number of days away from work in column K and the number of days with job restriction, in column L, if the employee experiences both. You must record all days away or restricted if the incident results in both. 
  • Entering the number of scheduled workdays missed or restricted instead of the calendar days. The “old” way was to record scheduled workdays. Now we must record calendar days. If an employee is injured and the doctor says they are out for 7 days, you must record 7 days, not just the days that he would have worked.
  • Recording an illness as an injury. If an employee suffers a flash burn from welding, this is an illness, so we check column M(2) Skin Disorder. If it is an injury, you should check column M(1).
  • Not recording the injury or illness on Form 300 within 7 calendar days. Once you become aware of the injury or illness, the clock starts ticking. If the incident is not reported until 2 days after it occurs, that is when the clock starts. So do not wait. Update logs weekly.
  • Not updating Form 300 during the 5-year storage period. Must update the Log when a newly discovered recordable injury or illness is identified. Also, must update the log if there are changes in the description or outcome during the 5-year storage period. You do not have to update the 301 or 300A. 

In 2022, OSHA issued 600 citations for failure to report a death, hospitalization, amputation, or loss of an eye within the appropriate time. In the same year, OSHA issued 360 citations for failure to electronically submit the 300A on time. 
There are so many details to recordkeeping that it is not hard to miss something. If you have any questions about recording an injury or illness, please do not hesitate to give me a call. After all, you are the reason I am here!

Written by Steve Savon, Safety and Regulatory Consultant, OEC

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