Top Ten Mistakes Made When Completing OSHA 300 Log

According to Chuck Paulausky, President of CP Safety & Environmental, employers from nonexempt industries with more than 10 employees are required to maintain the OSHA 300 Log for work-related, OSHA-recordable injuries. Beginning February 1 until April 30, employers are required to post their annual OSHA Summary Form 300A for the previous calendar year. This annual Summary needs to be displayed in a location accessible to all employees.

The Log can be downloaded at https://www.osha.gov/recordkeeping/RKforms.html. Because completing the Log can be challenging and confusing, here is a list of the most common mistakes made by employers:

OSHA 300 Log Top Ten Mistakes

  1. Failure to maintain the Log. There are some exclusions to this recordkeeping requirement, but it is required for most companies with more than 10 employees.
  2. Not using unique case numbers (Item A). This unique number will help keep the cases straight, and should transfer to the OSHA Form 301 which is filled out for each case.

  3. Failure to provide a detailed description (Items E and F). OSHA requires the injury type, location and source. However posting “Cut finger” just doesn’t cut it. A better entry would be, “Employee sliced tip of left index finger while using a utility knife to open a box in the stockroom.”

  4. Too many columns checked for classifying the case (Items G-J). OSHA wants only the most severe information about the case. Selections are listed left-to-right in order of severity: “Death (G)” is worse than “Days Away From Work (H).”  Days Away is worse than “Job Transfer (I)” and so on. Anything else is “Other recordable cases (J).”  CHECK ONLY ONE.

  5. Incorrect lost days count (Item K). The day of the injury is not counted as a lost-time day. Even if the employee is injured at the very beginning of the workday, goes to the clinic, spends the rest of the day at home and returns to work the next day, there is no lost time. One helpful point – what the physician says regarding “time off” determines lost time days, not the actual days lost.

  6. Over-counting for restricted and lost workdays (Items K and L). OSHA puts a 180-day cap for each case in each of these columns. Stop at 180 days, even if the worker has lost more time.

  7. Incorrect addition. Double-check page totals for each column, and add the correct numbers to the 300A Summary. The Log and Summary must match at the time of the annual posting. (Note: Any changes in lost or restricted days after the Summary is posted must be maintained on the Log, but not reported again on the Summary. If questioned, any difference between the two postings posted can be explained).

  8. Incorrect certifying person. The 300A Summary must be signed by the highest-ranking person at the site, not necessarily the person filling out the form.

  9. Confusing OSHA recordable injuries with Workers Compensation claims. Workers Comp and OSHA recordkeeping are two different systems, with different definitions! If your WC insurance denies a claim, it doesn’t mean the injury can be removed from the Log. And if an injury is accepted by WC as work-related, it doesn’t necessarily mean it must go on the OSHA Log. Usually the two are the same, but not always! Know the difference.

  10. Recording every injury or illness. Don’t record everything! During an inspection, OSHA will look at your Log to help decide how safely your company is performing. Reporting lots of incorrectly reported injuries looks bad. In addition, the injuries you record can be used by the Bureau of Labor Statistics to determine industry- and site-specific targeting programs for OSHA compliance inspections thus increasing your changes for a future audit. So while it is a bad idea to record injuries that aren’t recordable, under-reporting is citable offense! Know what to and what not to record. As a reminder, recordable injuries are: 1) work-related, 2) new and as yet unreported, and 3) those meeting specific recordability criteria. (All physician-ordered lost time and restricted duty is recordable.)

One final note: Post only the annual 300A Summary between February 1 and April 30. The rest of your Log contains sensitive employee information that should be considered private and confidential.

If you need more information on OSHA-recordability and other recordkeeping requirements, or want training on the OSHA 300 Log, contact Chuck Paulausky at (480) 694-1975, cpaulausky@www.cpsafety.net.