Here it is the first of December, there is a chill in the air and some of you have had to get the snow shovel out and maybe even the snow blower. The holidays are rapidly approaching and before you know it, it will be January 2011. I hate to throw a wet blanket on the end of the year, but in January each employer must complete the OSHA 300 logs and summary for the previous year and post the summary in a conspicuous space from February first through April thirtieth.

Also, some of you may get a Survey of Occupational Injuries and Illnesses reports for the previous year. In order to complete the survey you must have your OSHA 300 logs and summary report completed.

There are probably a lot of you out there saying, what is the OSHA 300 log, we haven’y had any accidents as long as we have been in business, we are a small company, we only have leased or temporary employees, etc…

First the OSHA 300 logs are required to be maintained on file at an employer’s place of business for a minimum of five years. These logs used to called the OSHA 200 logs prior to 2004. These logs have been required by OSHA (which is federal law) since 1971, so it really isn’t anything new. If OSHA shows up on your door step for a compliance inspection, the OSHA 300 logs are usually the first document they want to look at and review.

Are there any companies exempt from doing OSHA 300 logs? No. There are only partial exemptions. If your type of industry and SIC are on the partial exemption list with fewer then ten employees for the full year with no recordable injuries, then you would be exempt from doing the OSHA 300 logs. However, if you have one recordable injury or have more then ten employees (including temps) for one week during the year, then you would be required to complete the logs.

Don’t think you can get by with waiting until the end of the year to fill out the 300 log, 301 incident reports, etc., because CFR1904 of the OSHA standard states that injuries shall be entered into the logs within seven days of the injury. Waiting until the end of the year to do this can be a nightmare takes a lot more time in the long run and will not be accurate. This will probably cost you a citation and penalty before the rest of the compliance inspection even gets started.

Failure to enter all injuries, improperly classifies the injury, miscalculate the number of days away from work or on restricted duty will also add to the citation and penalty. How do I classify injuries and calculate day’s away and restricted duty? All of this information can be found in CFR1904 Recordkeeping Standards on the OSHA web site.

Starting in 2010 and running through 2011 Recordkeeping of OSHA 300 Logs is one of the campaigns OSHA is looking at hard during inspections. Failure to have the logs and supporting documents, failure to log all injuries, incorrectly classifying injuries and incorrect calculation of lost work days or days of restricted duty will now bring you a citation and penalties. In Arizona this year ADOSH has been issuing penalties of $400 for failure to have the 300 logs. In Indiana, Amtrac was penalized $7,000 for failure to have the 300 logs for the past five years. Lowe’s Home Centers Ind., out of Rockford, Illinois was fined $182,000 for numerous incorrectly entered data on the reports in several categories going back to 2008. Due to the fact Lowes was fined in past inspections for similar errors on the logs and had not corrected the problems made the penalties more expensive this time.

For those of you who may receive a Survey of Occupational Injuries and Illnesses from the U. S. Department of Labor in January, do not ignore it or throw it away. The information they are looking for has to be submitted within 30 days by federal law. In order to complete the survey you will need to have your OSHA 300 logs completed for the previous year. You can fill out the paper survey or follow in instructions on the form to go to their web site and submit the information electronically which makes it easier and faster. Failure to respond to the survey within the allotted time will result in notices and eventually a phone call from the local department of labor and possibly even OSHA for non-compliance. Once you receive a survey you may receive one every January for several years, so be prepared and it won’t be a surprise.

Sources: ADOSH, IOSHA, Federal OSHA and Safety Compliance Alert.

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