With the end of the calendar year fast approaching, most employers will need to review their OSHA 300 Log of work-related injuries and illnesses from 2022 to post the total number of injury/illness on their annual 300A form.
Even if no recordable injuries or illnesses occurred, the OSHA 300 Log and 300A annual form must still be completed, with submission of 2022 data due by March 2nd, 2023.
Your Responsibility as an Employer
In Minnesota, the state requires all employers with more than 10 employees—at any time during the calendar year—to maintain a 300 Log and post the total number of incidents on their annual 300A summary.
For states under Federal OSHA jurisdiction, there are exemptions for certain low-hazard industries.
What Is an OSHA 300 Log?
The OSHA 300 Log form allows employers to record the details of injuries and illnesses that occur at their workplace. This log ensures all incidents are reported in detail, which is then transferred to a 300A form.
For more information on OSHA recordkeeping, read our latest article.
Here are a few tips to help ensure 300 Log data is accurate:
- For each case entered on the Log, ensure you complete all entries in columns (A) thru (F).
- You’ll need to investigate further if it’s not evident that the work environment caused or contributed to a particular case.
Often, if the injury or illness occurred at work or symptoms appeared at work, it will be considered work-related.
However, if it’s not obvious that the work environment contributed to the case, you can investigate further to determine work-relatedness.
A Quick Example
A small employer had five hearing loss illnesses out of six cases entered in their OSHA 300 Log. This was very suspicious since the noise levels in the work areas were mostly below 80 decibels, except for a few specific areas with noise levels slightly above.
After further inquiring about the cases, it was determined that each of the five workers with hearing loss raced stock cars outside of work. The employer could then argue that the employees did not sustain the injuries at work based on the low noise levels in the work environment.
If in doubt, you have the right to investigate further. This includes getting an opinion from an occupational health professional.
What to Include In Your OSHA 300 Log
Only record new cases that meet the general recording criteria. A work-related injury/illness is recordable, for example, only if it results in the following outcomes:
- Days away from work
- Restrictions or work transfer
- Medical treatment
- Loss of consciousness
- Significant injury or illness diagnosis
Often, an establishment will record all reported incidents, including cases that only involve first-aid treatment.
It’s best to report any first-aid treatments on a separate form. Therefore, you should only record cases that meet the criteria on the 300 Log, which you will then use to complete the 300A. This avoids skewing data collected by OSHA and other entities tracking injury and illness information.
Review the first aid list in 1904.7(5)(C) if uncertain whether a case involved medical treatment or first aid. The list includes what is considered first aid, which would not be recordable.
Classification of Incident Cases
Each case must be appropriately classified. In columns (G) thru (J) on the 300 Log, you can only check one classification. Even if a case involves lost and restricted time, only one classification is checked.
If a case involves both lost and restricted days, check the classification representing the worst outcome—in this case, days away from work.
For a fatality, check only column (G). If no days away, job transfer, or restrictions occurred, then only check column (J) and be sure no days away, restricted or transferred days are entered.
Also, remember to:
- Count calendar days—not just scheduled workdays. Remember not to enter partial days for days away, restricted or transferred. Only use whole numbers. The counting starts the day following the injury/illness occurrence.
- Check only one of the columns (M1-M-6) that best describes the case.
- Double-check your addition to ensure the totals at the bottom of columns (G) thru (M) are accurate and ready to be transferred to the 300A.
Remember to post the 300A from February 1st thru April 30th in an area where notices to employees are typically posted. The 300A must be fully completed and certified by an owner, corporate officer, or highest-ranking company official at the site.
OSHA Injury Tracking Application (ITA)
All Minnesota employers with 20 or more employees—at any time during the calendar year—must submit their 300A information to the ITA available online.
Federal OSHA states have exemptions for certain low-hazard industries.
When you go to the ITA website, a pop-up will notify you of the need to connect your ITA account to a new login site. In addition, you’ll receive a link for guidance on how to connect to the new account.
First-time users of the new account will need to create an account.
Just remember that the submission of 2022 data is due by March 2nd, 2023!
Join us for a free webinar to help you prepare for OSHA’s March deadline. Our webinar begins on Thursday, January 19th, 2023, at 11 a.m. CST and is titled, “OSHA Recordkeeping 2022: Are You Ready for the Reporting Deadline?”
Sign up today for free and learn how to comply with OSHA’s bookkeeping requirements and prepare your forms for submission.
Support for Workplace Safety Issues
Questions about work-related injuries, illnesses or the OSHA Form 300A? OECS can help! We offer free initial phone consultations. Call 763-417-9599, email us at email@example.com or complete our contact form to ensure you don’t miss the March deadline.