New to the safety administration world? No problem, we got your back when it comes to helping you stay compliant with both federal and state OSHA requirements. Today, I’m going to dive into what you need to know to post your OSHA 300A log.
Each year, businesses are required to post their OSHA form 300A in a place where their employees are able to see it (i.e. near the time clock or break room). The form must be posted between February 1- April 30. The 300A form shows how many “industrial” injuries occurred the prior calendar year, including the number of days injured employees lost time or were on modified duty.
Federal state OSHA departments have the 300 forms online in PDF and Excel formats. The instructions are attached. I recommend downloading the Excel option so you can let the embedded formulas do the math for you.
To complete a thorough 300A form, you need to start with the 301 form and then complete the 300 form. The 301 form is used for each recordable injury and is not mandatory since insurance forms are also acceptable ways to record injuries. The 300 form is mandatory, but you do not post the 300 form since it includes private HIPAA information such as name of injured employee and medical results. The information you put on the 300 form is added up and goes on to the 300A. If you use the Excel version of the form, this will automatically happen for you. Once you have completed your forms, determine if the data needs to be entered into OSHA’s Injury Tracking Application. You can read more about that here.
Frequently Asked Questions
Policyholders often have many questions when they are filling out the forms. Here are a few answers to some common questions.
Q: If my employee was injured Nov. 1, 2020 and off work into 2021, do we carry over injury data from one calendar year to the next?
No, you do not carry over days lost or modified from one year to another.
Q: If my employee was off of work for 210 days, do I place 210 in column K on the 300 form?
No, the cap is 180 days.
Q: What proves a COVID-19 workplace/industrial injury for the OSHA form 300 log and what does OSHA require for a COVID case to be a workplace/industrial injury?
A COVID-19 case needs to be deemed a “workplace/industrial injury” before it can be posted on your 301 or 300. OSHA requires the following for a case to be considered a workplace injury:
- The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC).
- The case is work-related as defined by 29 CFR §1904.5.
- The case involves one or more of the general recording criteria set forth in 29 CFR §1904.7.
Q: Is the time my employee spends in quarantine considered “days away from work” for form 300 recording purposes?
No. Unless your employee also has a work-related illness that would otherwise require days away from work, time spent in quarantine is not “days away from work” for recording purposes.
Q: If my employee was off work due to a reaction to the COVID-19 vaccination, is that considered lost time and a recordable injury?
From May 21, 2021 through at least May 22, 2022, an adverse reaction to a COVID-19 vaccine is not a recordable injury, therefore it is not to be entered on your 300.
Remember, each year on the first of February your company needs to display their OSHA 300A summary in a common area wherever notices to employees are usually posted. A copy of the summary must be made available to employees who move from worksite to worksite, such as in construction and employees who do not regularly report to any fixed establishment. Contact your risk management consultant or visit the OSHA website for more guidance. Also refer to my other blog on the topic for more information on OSHA’s Injury Tracking Application requirement.