Do You Follow OSHA Safety Log Regulations?

PROs with 10 employees or more are required to complete federal safety logs and post the results every February

Do You Follow OSHA Safety Log Regulations?

Jeff and Terri Wigley

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Question: Could you please provide some clarity around the OSHA 300 (Occupational Safety and Health Administration) Safety Log process? I have heard bits and pieces about the process and have never really understood the purpose or the requirements.

Answer: This is a very timely topic. The bottom line is that all portable restroom companies with more than 10 employees are to complete and post the OSHA 300A Log for the previous year in a visible location in the office from Feb. 1 to April 30 each year. Is your log posted now as your read this February column?

We hope this is not a surprise to most PROs. If this is “new news,” please continue to read and we will do our best to describe the program and to simplify these rather complex procedures.

What is this OSHA program?

The OSHA Form 300 Log is a federal requirement designed to report safety in the workplace. In 2002, OSHA established the current posting dates for Form 300A in the workplace. This form along with Form 300 and 301 compose this program.

What are the required forms?

• OSHA Form 300 is entitled “Log of Work-Related Injuries and Illnesses.” This document lists each job-related injury by employee name, job title, where the injury or illness occurred, description of the injury or fatality, and total days away from work. This listing is maintained in a file, and the records are to be kept for a minimum of five years. Our recommendation is to retain all of these files for a longer period of time and to store them with the company’s personnel records.

• OSHA Form 300A is entitled “Summary of Work-Related Injuries and Illnesses.” This is the form that must be posted annually. This document provides only three areas of summary information, which protects individual confidentiality. The first section summarizes the number of cases from the previous year, total number of cases with days away from work and total number of cases with job transfer or restriction. The second section provides a total number of days away from work for all cases, as well as total number of days of job transfer or restriction. The final section provides summary-only information concerning types of injury and illness types. If the company has no incidents, “zero” must be recorded and the summary form is still to be posted for the required three-month period.

• OSHA Form 301 is entitled “Injury and Illness Incident Report.” This provides the details of each incident, the employee involved, the diagnosis, physician(s) involved, hospitalization details (if applicable) and all other pertinent information concerning the incident.


How does one obtain these forms?

The OSHA website is www.osha.gov. All three forms may be downloaded from this site, and questions and answers can be accessed. 

What is reported to OSHA and when?

Effective in 2015, the following timelines must be observed:

• Work-related fatalities must be reported to OSHA within eight hours.

• Work-related hospitalizations must be reported within 24 hours.

• Work-related amputations, loss of an eye or other serious injury must be reported to OSHA within 24 hours.

Is there an electronic reporting requirement for Form 300A?

Yes. Two categories of companies must electronically report to OSHA: Companies with 250 or more employees, and companies with certain NAICS (North American Industry Classification System) codes with more than 20 and less than 250 employees are to electronically submit their reports on a designated annual schedule. Our research revealed that NAICS Code 5621 – Waste Collection – is one of the designated categories, but our specific NAICS Code 562991 – Septic Tank and Related Services – is not. We mention this only for PROs who may have other types of businesses in the Waste Collection industry.


Are there penalties for not maintaining an OSHA 300A Log?

Yes. In the event of an OSHA inspection, failure to maintain and present the 300A Log can result in a fine of up to $8,000 for each year of violation. 

What are the most common mistakes when completing the OSHA Log?

According to OSHA, the top five errors are:

• Assuming that light duty is not a work restriction

• Dismissing the employee statement as not accurate or not usable as a reference

• Failing to report the injury because the employee did not report it in a timely manner

• Failing to record medical treatment

• Forgetting to keep track of lost workdays during lengthy, long-term treatments

What are the benefits of this program?

Safety is one of the cornerstones of a successful company. The OSHA Safety Reporting Program allows PROs to monitor safety in the workplace, identify possible safety issues and create an atmosphere where safety and safe working conditions are paramount in importance.

Are there programs to voluntarily become involved with OSHA in order to further improve safety?

OSHA does make programs available to businesses that would like to work cooperatively with the agency to help prevent accidents and injuries in the workplace. Please consult your local OSHA office about these opportunities. Finally, some states have OSHA-approved State Plans where cooperative assistance is also available.

FINAL THOUGHTS

OSHA and its rules and regulations are the ultimate arbiter of this program. Please consult the OSHA website for specific questions or concerns. In addition, if you would like to share any further information about this rather complex topic or to add your own experiences about OSHA Safety Reporting, please let us know and we will include the information in a future column.

If you haven’t already, get those 300A Logs posted now!



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