It’s that time of year when affected employers need to finalize their OSHA 300 log data of work-related injuries and illnesses which also means it’s the time when the most common OSHA recordkeeping mistakes happen.
Please note that some of these mistakes can result in potential fines or penalties:
1) Not separating OSHA logs by establishment. OSHA requires a separate 300 log and 300A summary for each business establishment. Companies that have multiple locations must have a separate set of records for each location if those locations are expected to be in operation for one year or longer.
NOTE: It is possible for a company to lump several locations together under one set of logs only if all of the requirements are met under OSHA definitions.
2) Incorrectly claiming a “small business” exemption. OSHA states that employers with 10 or fewer total employees for the entire calendar year need not keep these logs, but a lot of smaller employers may not be aware that they have exceeded the “10-employee rule” by hiring temporary and/or seasonal labor through the previous year. OSHA says the exemption for small companies does not apply if the total employee count exceeds more than 10 workers on the payroll at any time the previous year.
3) Only counting company workdays on the lost time and restricted duty columns of the form. Current OSHA standards state that you must count all calendar days the worker did not return to work whether the employee was scheduled to work them or not. Keep in mind that holidays, weekends and vacation days all count.
The OSHA 300A summary form must be posted at each establishment as of February 1st and must remain posted until April 30th. The OSHA website (www.OSHA.gov) is a great resource for common questions regarding recordkeeping. The Flanders Group is a full service agency offering Workers Compensation, Commercial Insurance, Health and Benefits. We can be reached at 800-462-6435 or [email protected].