Although it’s a hectic time of year, The Flanders Group wants to share some practical advice for OSHA logs sooner rather than later. It might be tempting to put off until January so you can meet the required February 1st posting deadline however, ensuring that your company’s OSHA logs are complete and compliant can be time-consuming.
In addition, OSHA is currently laying the groundwork to pass a requirement that companies must electronically file their OSHA 300 and 300A forms. This not only will help OSHA identify patterns and underreporting, but it will also make employers more vulnerable to record keeping inspections
Aside from obvious issues such as not posting the OSHA 300A during the required period (February 1st-April 30th), or not keeping OSHA logs at all, there are several other lesser-known common mistakes that employers often make which can result in inaccurate OSHA record keeping.
Relying On Workers’ Compensation Loss Runs
It’s tempting for employers to request a loss run from their workers’ compensation carrier and use it as the primary source for completing the OSHA log. While most workers’ compensation claims meet the OSHA record keeping criteria as reportable, some may not. Conversely, many minor work-related incidents will not result in a workers’ compensation claim, but may meet OSHA record keeping criteria. It’s important that you thoroughly review all of your incident reports and subsequent documentation to determine if medical treatment beyond first aid, restrictions or lost time beyond the date of injury were involved.
Incorrectly Identifying Lost Time
Another common mistake is the misconception that lost days only need to be recorded once the employee has started to miss scheduled workdays. The OSHA regulations state that lost work days are based on the calendar days that the employee was rendered disabled for work.
Example: You have a worker who typically works Monday through Friday who gets injured on Friday morning and is treated by a doctor on the date of injury. The employee is taken out of work with a doctor’s note returning him/her on the following Tuesday. Proper recording on the 300 log would note three days away from work (Saturday, Sunday and Monday) , even though he/she only missed one scheduled work day (Monday).
Neglecting to Update Logs from Prior Years
It can be difficult enough to stay on top of the current year’s log, let alone having to update logs from years ago, but any work-related injury that results in a condition that meets OSHA reporting criteria, must be recorded in the log in the year that the injury originally occurred.
Example: An employee has a shoulder injury in 2013 and works with restrictions for three months. Then, in early 2015 the same employee has surgery due to the 2013 injury and is out of work for two months. The employer is responsible to update the 2013 log with the new period of lost time. In addition, the classification of the case must be changed from a “job transfer/restriction” case to a “days away from work” case. This update should be reflected on both the 300 log as well as the 300A summary.
For more OSHA record keeping tips and guidance, contact Tiffany Passmore, The Flanders Group Director of Client Services at 800-462-6435 ext.234.