Who updates your site's OSHA 300 Log of work-related injuries and illnesses?

I you are not the person, please forward a copy of this reminder to them now.

Most companies have production and/or safety leaders completing incident reports and presenting the information to someone in HR, and HR updates and maintains the OSHA 300 log (since they have secure offices).  All non-governmental companies that have 10 or more employees are required to maintain a OSHA 300 log each year.

January is the time to check the OSHA log (of work-related injuries & illnesses) for the previous year, then finalize and print a summary of the incidents/illnesses for the year on the OSHA 300A (annual summary form). The OSHA 300A form must be signed by the local President or GM, then posted in the workplace for employees to view. The 300A summary must be posted for all of February through all of March, but most companies keep it posted year-round. Note that companies are not allowed to post the OSHA 300 log itself (privacy issue), so only post the annual 300A summary form.

Since your company may be uploading OSHA 300A data to an on-line OSHA site (named ITA) by March 1, you want the data to be accurate. Note that industrial companies with 20 or more employees must put their 300A data on the OSHA site. Every January, scan through your OSHA 300 log of cases and check for the following:

• Make sure to remove any cases that are not OSHA recordable cases. These would not be OSHA recordable: Not work-related, only basic-first aid was needed at the clinic and the worker was back at work the next day.  These would be OSHA recordable: When there are stitches, an amputation, prescription medications are prescribed, the worker does not return to work the next day, the worker returns with Doctor's list of work restrictions.
• Be careful with how you handle injuries of temp workers. OSHA says any OSHA recordable case must be included on the OSHA 300 log of the employer that is managing the worker during the shift or hour to hour. This means if your company uses temps, and the temp firm does not have a crew leader who instructs and manages the temp workers throughout the day, the host company needs to include OSHA recordable cases on the host company's OSHA log. You might want to put a note on the OSHA 300 log and the 300A summary when a case involves a temp worker.

For more info on completing the OSHA 300 & 300A forms:

Instruction Overview for OSHA Recordkeeping

To complete your OSHA 300A Summary form  you will need your OSHA 300 log from 2023, the average number of employees during 2023, the business SIC or NAICS code, and the cumulative number of manhours worked by employees during 2022. Most accounting /payroll systems can provide the manhours data (but if not, you will need to calculate based on number of people and average number of hours /yr).

Note (for February):
Industrial companies with 20 or more employees will be required to post their 300A data online for OSHA  by March 1, 2024, as usual. You will use the same login.gov account you set-up last year to post the data on the  OSHA ITA site (Injury Tracking Application).  Note that the  login.gov and the ITA accounts should both use the same same e-mail.

There is a new requirement this year for sites with 100 or more employees during the year (and in designated industries) to also share their OSHA 300 log and OSHA 301 incident forms with OSHA. Printing was not on the list of industries designated industries. To check whether your site is in one of the designated industries with new additional data sharing requirements, follow this link:

https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppB

Impact Safety helps manufacturing sites build and maintain effective safety programs that employees are proud to participate in. We have helped over 350 manufacturing sites (over 20,000 employees) with their safety journeys since 2005. We are based in Arlington, Texas. We provide consulting and training services to sites in Texas and surrounding areas on-site and on-line. Our on-line training is available for clients across the US. Our largest niche is serving printing companies. Contact Joe Eudy ([email protected]) if you feel your company needs to boost safety to a higher level!