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.

Emergency Egress

It’s well known that after John Wilkes Booth shot President Lincoln, he leaped from the President’s box to the stage where he tripped and fell, breaking his leg. What’s not well known is what he tripped over. According to some first-hand accounts, as John Wilkes Booth was trying to make his exit, he tripped over the American flag.

Egress is the way out of a room or building. In the event of an emergency, egress sounds like a simple thing. Leave the building! However, from the viewpoint of OSHA, egress involves a number of very critical requirements. Imagine needing to get out of a strange building in a hurry and having doors blocked, not well-lit or not marked as an exit.

In order to comply with some of the requirements of Subpart E of the OSHA standards, ask yourself these questions:

  • Are all exits marked with an “EXIT” sign and illuminated by a reliable light source?
  • Are exit signs provided with the word “EXIT” in lettering at least 6-inches high and the stroke of the lettering at least ¾-inch wide?
  • Are exit doors side-hinged?
  • Are all exits kept free of obstructions and unlocked on the inside?
  • Are doors, passageways, or stairways that are not exits or access to exits–and which could be mistaken for exits–appropriately marked “NOT AN EXIT” or some other words indicating actual use?
  • Are the directions to exits, when not immediately apparent, marked with visible signs and well-lit?
  • Are at least two means of egress provided from elevated platforms, pits, or rooms where the absence of a second exit would increase the risk of injury from hot, poisonous, corrosive, suffocating, flammable, or explosive substances?
  • Are there sufficient exits to permit prompt escape in case of emergency?
  • Are special precautions taken to protect employees during construction and repair operations?
  • Are all exit routes arranged to avoid high-hazard areas?
  • Is the number of exits from each floor of a building and the number of exits from the building itself appropriate for the building occupancy load?
  • Where ramps are used as part of required exiting from a building, is the ramp slope limited to 1 vertical inch per horizontal foot?
  • Where exiting will be through frameless glass doors, glass exit doors, storm doors, etc., are the doors fully tempered and meet the safety requirements for human impact?

Do not rely solely on this list. Always refer to the OSHA standard and applicable NFPA and other local fire and building code requirements when determining compliance for your facility.

This article was originally published in the August 2006 issue of the Journal of Environmental Management-Arizona. Ideas for stories come from a variety of sources, including online news and Richard Hawk of Making Safety Fun.

Fall Prevention Tip

Are your employees “catapedamanics”? They are if they are obsessed with jumping from high places. If their thing is falling from high places, like ladders or scaffolds, the correct term is either “unsafe employees” or “unsafe employer”!

Falls are one of the most frequent causes of employee injuries and are also related to several of OSHA’s top ten list of violations, especially in the construction trades. Your responsibility as an employer is to provide the training and tools to prevent employee falls, whether this includes fall protection devices–such as harness and lanyards–properly erected scaffolding, safe ladder use, or simply good housekeeping. If you don’t provide these things, you may end up “taking the fall” for your employees.

Compliance Tip

Two trucks loaded with thousands of copies of Roget’s Thesaurus collided as they left a New York publishing house. According to a newspaper report, witnesses were astonished, stunned, startled, flabbergasted, taken aback, stupefied…

It takes a lot more than a thesaurus to understand the meaning of complex OSHA and EPA regulations. The OSHA requirements for General Industry alone fill almost 1000 pages! These extensive federal, state and local regulations can be difficult to follow, but the agencies sometimes provide guidance which may make the task a bit easier. Remember that not knowing what’s needed is not a defense; what you don’t know can hurt you! If you need help figuring out what applies to your operation, contact CPSE. We’ve got what you need; expertise, proficiency, know-how, competence…

Warning Signs Tip

A man enters a little country store and sees a sign reading “Danger! Beware of Dog.” Just inside the door, he sees an old hound dog lying asleep on the floor. “Is that the dog folks are supposed to beware of?” says the man to the clerk. “Yep,” replies the clerk. “Before I posted that sign, everyone kept tripping over him.”

Warning signs can be a very effective way of preventing accidents, and in most cases these are required by regulation. Requirements include signs for emergency egress, signs for machine and electrical safety, signs locating fire extinguishers, signs for safe chemical storage and use, and many more situations. Many of the OSHA regulations have signage requirements. Failure to have the required signs can result in injuries, property loss, and non-compliance.

Managing Your Workers’ Compensation Costs

Joe was hardly an ideal worker. He had been laid off five times in four months. Shortly after starting a new warehouse job, he lost control of a forklift and drove it off the loading dock. His boss told him that he’d have to withhold 10% of his wages to pay for $5000 in repairs. “What a relief!” exclaimed Joe. “I’ve finally got job security!”

Unsafe employees can really impact your bottom line through production and equipment losses, retraining, and workers’ compensation costs for injured employees.

In Arizona, workers’ compensation insurance is required for all companies with one or more company employees, whether those workers are part- or full-time, minors, aliens or family members. This insurance is not required for contract workers, casual workers or workers not part of the employer’s usual business. Note: Uninsured employers can be assessed a first-time $1000 penalty for failure to provide insurance for its employees. The amount of the fine can increase over time for repeat offenses.

The insurance is designed to pay for the medical costs and compensation for lost wages due to workplace injuries. According to the Arizona Corporation Commission, “Workers’ Compensation is a ‘no-fault’ system in which you (the injured worker) receive medical and compensation benefits no matter who caused the job-related accident.” There are some exceptions, however. For example, an employee is not entitled to workers’ compensation benefits for injuries that are “purposely self-inflicted.” For more information about these requirements, contract the Arizona Corporation Commission or your insurance carrier.

The cost of workers’ compensation insurance is based on several factors, including the number of employees, payroll, type of work (risk) involved, and a number of other things. The calculations are based on a system of worker classification established by the National Council on Compensation Insurance (NCCI). Almost all states use this system. Note: Mis-calculation of your employees can impact your workers’ compensation costs, so make sure your employees are property classified.

Once your basic insurance rate is established, another factor comes into play. This is the “Experience Modification Factor” or E-Mod. The E-Mod looks at the cost of your workers’ compensation claims over a previous three-year period and compares it to similar industries, as established by NCCI. The average for your industry is 1.0. If your claims have been less than the industry average, your E-Mod will be <1.0. If you have had higher than average claims, your E-Mod will be >1.0.

The E-Mod directly impacts your insurance premium because your basic insurance rate is multiplied by your E-Mod. For example, let’s compare two identical companies. Company A does a good job of reducing injuries and keeping workers’ compensation claims down. Company B has more injuries and higher related costs.

COMPANY A COMPANY B
Basic Insurance Rate $100,000 $100,000
Experience Modifier (E-Mod) 0.8 1.2
Modified Premium $80,000 $120,000

Difference:

$40,000

As you can see, reducing workers’ compensation claims will reduce your insurance premiums. There are several ways to do this:

  • Early-Return-To-Work (ERTW). There are two basic types of claims, Medical-Only and Indemnity or Lost Time. Medical-only claims are just that — claims involving medical costs without lost time. Indemnity claims are claims in which the injured employee has lost time from work. The insurance company pays the injured employee for a percentage of the time lost. The cost for lost time is usually much more than the medical costs. When the E-Mod is calculated, only 70% of the medical costs are factored in, but 100% of the indemnity costs are included. So minimizing lost time makes good cents.
    • Establish an ERTW program. You can only return an employee to work if the physician on the case allows it, but make sure the doctor knows what the injured employee’s job entails and his or her limitations, then find tasks that the employee is capable of performing. Finding temporary light-duty or alternate work for injured employees is easier than you think. Look at the employee’s regular job. Are there tasks or functions that the employee can still do? Consider cross-training or temporary job-trading to allow the employee to work until fully recovered. I’ve even heard of employers who donated their paid employee’s time to non-profit organizations to get them off the insurance books.
    • Make your ERTW program a part of the written company policy and make sure employees know about it.
  • Active Claims Management.
    • Maintain close contact with the insurance company to ensure that claims are being managed on their end and that your E-Mod and employee classifications are correct. Be sure to find out if overtime should be included in the reported payment (this is not required in some states). Report any business changes to the carrier that might affect your coverage.
    • Require your employees to report injuries as soon as possible, and report the claim immediately. Early reporting can (1) keep costs down, (2) start the management process, (3) prevent litigation, and  (4) return the injured worker to full duty sooner.
    • If you feel a claim should be closed, follow up. Too often communication is not well-maintained, allowing claims to stay open and on the books. Amounts that are still in reserve (unused) on the claim will count as costs until the claim is closed.
    • Direct where the employee goes for initial treatment. This will give you some control over the direction of the claim. However, the injured employee has the right to choose further treatment. Stay in contact with this new physician as well. Directing initial treatment is allowed in Arizona, but not in all states.
    • Keep in touch with the medical provider for each claim to insure that the medical treatment is being followed. If an employee fails to do prescribed therapy or misses appointment, the claim can be contested.
    • Stay in contact with the injured employee. Make sure their recovery is progressing and encourage them to stay on track with therapy and other treatment.
    • Watch for fraudulent claims. Employees may be tempted to get a personal injury covered under workers’ compensation or “extend” their time off for an injury. If you suspect that a claim may not be legitimate, indicate this on the industrial injury reporting form, and let your insurance carrier know.
  • Reduce Injuries. This is really the place to start. Anything you can do to prevent your employees from being injured in the first place will keep your workers’ compensation costs down. This means having an effective safety program. This program needs to include:
    • Written safety policy
    • Management commitment and supervisor accountability
    • Evaluation of your company’s operations and risks
    • Safety training
    • Safety Committee
    • Personal protective equipment
    • Accident investigation, including causes, corrective actions and follow-up
    • Drug and Alcohol policy. The U.S. Government estimates that the cost to businesses each year from drug and alcohol abuse is $100 BILLION! You should have a written policy that is properly worded to include specifics of what is prohibited, types of testing, enforcement and penalties.

How much an one accident cost a company? It’s more than the workers’ compensation insurance cost. You have to factor in things like lost time for other workers and supervision, lost in team efficiency, new worker training, equipment downtime, etc. Consider an accident with a combined cost of $5000 for a company that operates on the 5% profit margin. The company must generate $100,000 in additional sales to cover that cost!

Managing your workers’ compensation program is one step in reducing the cost of injuries. Also, developing an effective safety program will help keep employees like Joe from driving off the deep end, and taking your company with him!

This article was originally published in the August/September 2009 issue of the Journal of Environmental Management-Arizona. Ideas for stores come from a variety of sources, including online news and Richard Hawk of Making Safety Fun.

COMPANY A

COMPANY B

Basic Insurance Rate

$100,000

$100,000

Experience Modifier (E-Mod)

0.8

1.2

Modified Premium

$80,000

$120,000

Difference

$40,000

Are Your Employees Cows or Crows?

You’re driving down a country road, and up ahead you see a crow on one side of the road, and a cow on the other. You honk your horn to let them know you’re coming and what happens? The cow just stands there processing the grass–in one end out the other, like it does every day, blissfully unaware of the danger. It doesn’t even look up. On the other side, the crow is paying attention and probably took off even before you honked your horn.

How aware are your employees? Are they able to do the same task each day and still be aware enough to “fly away” when they are at risk? A good safety program keeps your employees aware of the risks from their everyday jobs, through supervisor responsibility, rules and training, employment involvement, and attention to “near misses.”

Supervisors

Your supervisors are the front line in the battle against injuries. They know their employees and the processes. They are out there every day in control of the operations. Make sure your supervisors are aware the risks that their employees face and what’s required to reduce those risks. When it comes to maintaining compliance, OSHA often looks at both management and supervisors when deciding who is liable for a fatality or serious injury.

Here are a number of things that you can do to help your supervisors protect employees and the company:

  • Provide supervisor awareness training to make sure they know their responsibilities.
  • Make supervisors accountable for safety; build safety into their annual performance reviews.
  • Have supervisors do regular documented safety inspections.
  • Use supervisors to provide some of the safety training, e.g., “tailgate” or “benchtop” meetings.
  • Make supervisors responsible for doing detailed accident investigations that include causes and corrective actions, with follow-up.
  • Ensure that supervisors send the message that there’s always time to “do it safely.”

Rules and Training

Your employee manual probably includes a list of results meant to protect the company from liabilities of sexual harassment, theft, improper Internet usage, etc. You probably also have methods of enforcing these rules, such as “third strike” policies. You should do the same with safety rules. There can be general safety rules outlined in the employee manual and job-specific safety rules defined in your safety manual, policies, and standard operating procedures.

Regular, repeated training will help keep employees aware of the rules. Enforcement of the rules will help bring the message home. Many construction companies rely on weekly tailgate meetings at the job sites to keep employees aware. You can have quick meetings in your workplace that focus on specific topics of concern [a good opportunity for supervisors]. Use occurrence of injuries and near misses to help drive your training topics. Repeated training can help keep safety “up front” in employees’ minds.

Communication

There are lots of ways to communicate safety to employees. Think about these methods:

  • Publish safety newsletter and handouts
  • Insert paycheck safety reminders or tips
  • Post safety posters
  • Circulate safety incentives
  • Count “no lost workdays”
  • Include safety issues in plant meetings to keep awareness up
  • Post Safety Committee minutes

Employee Involvement

Workers will be more responsive to safety requirements if they are involved in the process. Some ideas for instilling a sense of “ownership” include:

  • When doing Job Safety Analysis, make sure you talk with the employees involved in the operations. After all, they are the ones who are doing the work and will have an “insiders” viewpoint.
  • Provide a safety suggestion box, and make sure to follow up with the employees making the suggestion. Even if you don’t act on the suggestions, let them know why. That way, they know that they’re not being ignored.
  • Have a Safety Committee that includes workers from various departments. Don’t just rely on supervisors and managers to make up the Committee.
  • Make sure that employees know they they won’t get into trouble if they communicate safety issues. You would be amazed at the number of employees, especially from certain cultures, who think they they’ll be fired for “complaining” about safety.

Near Misses

Near misses are accidents just waiting to happen. Near misses are those accidents that almost happen. Near misses are what make injuries predictable. If you ignore them, you’re increasing the likelihood that someone will be hurt. OSHA statistics indicate that for every fatality or serious injury that occurs, there are 29 moderate injuries and 300 near misses! Think of the amount of pain, damage, and expense that could be saved if you recognized and responded to the first near miss–before it became an injury or fatality.

Most accidents result from one of two things:

  • Unsafe conditions. These are things that can usually be fixed or controlled.
  • Unsafe acts. These are behavioral, such as when employees put themselves and others at risk by not following the rules.

Ensuring that all the employees are looking out for unsafe conditions, unsafe acts and near misses and are empowered to dosomething them will go a long way towards reducing injuries and improving employee awareness.

They say that when a person is wide awake, alert, and mentally active, they are still only aware of 25% of what their body is doing. When your employees are working with machinery or chemicals, they need to be operating at 100%, including at 75% that their brains aren’t paying attention to.

Safety awareness is critical to avoiding injuries. So what’s it going to be for your employees? Cows or Crows?

The article was originally published in the October/November 2009 issue of the Journal of Environmental Management-Arizona. Ideas for the stories come from a variety of sources, including online news and Richard Hawk of Make Safety Fun.

Safety Awareness Tip

An American Admiral, spotting a blip on the radar screen, told his radio operator to send a message to the other ship to alter its course 15 degrees. The reply came back, “You need to change your course 15 degrees.”  The Admiral grabbed the microphone and snapped “You change your course.  I am an Admiral in the US Navy!” To which a calm voice replied, “And I am a lighthouse.”

Safety is very much a matter of attitude. It’s important for your employee to know their limitations and liabilities, and to be open to new ideas and change. Employees will “buy into” your safety program if they feel involvement and ownership. An effective safety training program is one way to get this point across.

National/Federal Links

Occupational Safety & Health Administration (OSHA)
Environmental Protection Agency (EPA)
U.S. Department of Transportation (DOT) – Hazardous Materials

Arizona Links