OSHA 300 logs (300, 300A and 301) document the workplace injury and illness records and ensure they are properly displayed for employees and appropriate management to view. The following are some key aspects of understanding when and how to complete the logs.

These logs are for companies with more than 10 employees. The 10-employee count includes part-time employees but not contract workers (If you give them a W-2 it counts, if you give them a 1099 they do not count). For most temporary employee contracts, the temp agency is not responsible for completing the forms for the temp employee.

OSHA does not want injuries recorded on more than one company, so the temporary agency contract should be used to determine who records the injury. When coming up with the total headcount, remember, office employees do count toward the total employee headcount. If you are subject to an OSHA inspection, OSHA will look at payroll records to determine the counts. To do this, OSHA will simply total the number of paychecks written in a year and divide by the number of pay periods to get an annual average number of employees.

If a person leaves and is replaced, the counts will not be cumulative. Small overlaps when replacing an employee for training purposes would need to be documented and should not count both as employees. OSHA is different from the IRS, which will look at the three Cs (care, custody and control) to determine headcount. Form 300/300A and instructions are available on online at www.osha.gov, or call your local OSHA office.

Injuries are required to be added to Form 300 within seven days of the injury. Injury statistics are recorded based on the year the injury occurred — so a December injury in 2018 with days missed in 2019 would have the days recorded on the 2018 form. OSHA forms 300 and 300A must be retained for five years. Be sure to completely fill out the forms and maintain onsite. Each year, it is good to put a calendar tickler to remember to review your compliance policies. In addition, please incorporate these into your onboarding and training program for new employees and managers.

Forms 300 and 300A must be signed by the highest local authority, typically a company officer or director; or in separate company operations, the highest level of authority within.

As a reminder, the 2019 reporting deadline for submitting the OSHA Form 300A is March 2. This is a different deadline than what you are used to based on past reporting deadlines. To learn more about the new reporting deadline visit the ASA website at www.asa.net. In addition, you will find additional resources and information on the ASA website related to OSHA illness and injury reporting requirements.

Also, don’t forget that the annual OSHA 300 submitted forms are used by the ASA Safety Committee in determining the recipients of the ASA Safety Award. The ASA Safety Award is designed to elevate the awareness of the importance of safety in all aspects of the PHCP and PVF industries and also to recognize ASA members that have the lowest incident rate for non-fatal injuries and illnesses in the previous year. For more information about the ASA Safety Award, visit www.asa.net.

Note: If you are a safety/environmental health professional and your company is a member of ASA, we would like to hear from you. ASA maintains a database of member company safety/environmental health professionals and we use the mailing list to send safety-specific information to those having an interest. To get your name on the list please contact Jim Kendzel, vice president advocacy, at jkendzel@asa.net. We also are looking for ASA member safety/environmental health professionals to serve on the ASA Safety Committee. If you are interested, please let Jim Kendzel know.