Making Sense of the OSHA 300 Log and OSHA Forms 300A and 301
Many of you have been neck deep in the stressful time that is the OSHA 300A summary form submission and either grateful you don’t have to then submit your 300A data directly to OSHA or frustrated by this next step. Others of you might be thinking, I don’t even know what the 300A is or why February 1st and March 2nd are important.
Let's take a few moments to get on the same page and move forward together.
OSHA has required employers to record work-related injuries and illness on government provided forms since before bell bottoms were fashionable (the first time). Originally the form was called the OSHA 200 log and then, in 2002, the OSHA 300 log was born. All these years later, OSHA’s recordkeeping requirements remain the same with topical iterations that occur occasionally.
The core of the requirements focus on three forms which are:
- The 300 Log
- Form 301
- Form 300A
You can take day-long courses on the ins and outs of these forms. And you can find courses at every health and safety conference in the country, or at an OSHA Training Institute. There is even a handy training module on OSHA’s website. This post is not one of those courses, however, it is a brief overview of these important forms, some guidance on how to simplify this harrowing annual process and links to helpful resources.
Throughout this post, you’ll notice links to specific OSHA web pages to bookmark for help in the future. The OSHA website has a vast repository of helpful resources IF you can find them. To save you time, we’ve complied key links:
- OSHA’s Recordkeeping Tutorial
- Industries exempt from OSHA Injury & Illness Recordkeeping and Reporting Requirements
- Is this situation recordable? OSHA’s FAQ
- Detailed Guidance for OSHA's Injury and Illness Recordkeeping Rule
- COVID-19 recording guidance
- Where to submit your OSHA 300 Log
- Establishments who must electronically submit 300A data directly to OSHA by March 2
- OSHA Forms for Recording Work-Related Injuries and Illnesses (including instructions & DART rate calculation formulas)
- How you compare to other industries - U.S. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program
- Bureau of Labor Statistics Incidence Rate Calculator and Comparison Tool
Now, let’s review each of the three forms.
The OSHA 300 Log
All employers are required to keep this log unless you have 10 or fewer total employees in a calendar year or you are an exempt low-hazard industry.
The 300 log is where you record or log all of your work-related injuries and illnesses that occur in a calendar year. You are also required to keep one of these logs for each address where you have employees working. That is worth repeating: you are required to keep a log for each address where employees work. If you have hundreds of locations, you have hundreds of individual 300 logs.
OSHA provides this log in excel format on their website – do you have to use their exact form? No, you do not. You can if you like. However, you can use something more modern and easier to manage as long as the same exact information is being collected. HSI does provide Incident Management SMS software that allows you to collect data electronically throughout the year and quickly export it in OSHA’s exact format when you’re ready to post the 300A in your workplace and/or submit it to OSHA. This proves to be a valuable time-saver come January when these reports need to be prepared and helps manage your workplace all year.
The biggest challenge employers have with these logs is knowing which injuries and illnesses are or are not considered recordable according to OSHA. Some employers believe if something results in a workers’ compensation claim, then surely it goes on the log— that, however, is not necessarily a good rule of thumb to live by and may result in overreporting. Others believe that if an injury or illness is deemed not compensable through workers’ compensation, then it does not need to be logged. Again, that would be false.
Many of those day-long courses mentioned previously spend the majority of time teaching what is and what is not recordable.
What is recordable are injuries and illnesses that are work-related that meet certain severity criteria. OSHA defines an injury or illness as an abnormal condition or disorder and can include:
- Skin diseases
- Respiratory conditions
- Subjective symptoms/aches or pains
Exposures that do not result in signs or symptoms are not considered injuries or illnesses and therefore would not be recorded on the log. For example, if an employee is exposed to chlorine and doesn’t exhibit any signs of symptoms due to exposure, even if it involved preventative medical treatment, it is not recordable under the rules.
Confusing, isn’t it? You are not alone. There are so many twists and turns that OSHA has developed an enormous FAQ where people have submitted specific scenarios and OSHA answered each question explaining if the case is recordable or not. There are 622 questions in the FAQ at the time of this writing and you can search by keyword.
One of the advantages of using an electronic system to record injuries and illnesses is that some of them have intelligence built-in to guide you through whether a particular case meets recordability criteria.
Sometimes, it’s also tricky to determine if something is work-related. OSHA says cases that are “caused by, contributed to, or significantly aggravated by events or exposures in the work environment” are considered work-related for recordkeeping purposes.
There are certain activities that occur in the work environment that OSHA does not consider work-related. For example, injuries resulting directly from eating, drinking, or preparing one’s own food at the workplace are not considered work-related.
Work-related injuries and illnesses that result in death, loss of consciousness, days away from work, restricted work activity, transfer to another job, or medical treatment beyond first aid must be recorded on the OSHA forms. There are also special instructions on how to handle and record needlestick or sharps injuries, hearing loss, and cases of tuberculosis among other things. You can find that detailed guidance as well as other recording details in OSHA's Injury and Illness Record keeping Rule FAQs.
In addition, there is special guidance on how to record or not record cases of COVID-19–which you can find in the OSHA Coronavirus Guidance.
OSHA Form 301
Form 301 is something you fill out for each individual recordable injury or illness. Form 301 collects specific details about the individual and what happened. This is the form often used the least by employers. Why? Because the OSHA law allows for state workers' compensation forms, insurance forms, or other reports as substitutes as long as the substitute contains all the information asked for on Form 301. Many employers choose not to double-up on collecting information in two places and use instead of a First Report of Injury Form, for example.
OSHA Form 300A
The 300A is a summary of everything on the 300 log and is the form everyone is required to post in their workplace by February 1st every year. If you just read that and thought “what? I have to post this?” then please make sure it’s the first thing you do when you’re done reading this. You must have a 300A for each 300 log you maintain; if you have fifty 300 logs, you need to produce fifty 300A forms.
If you recall the image of the 300 log, it has columns. On the 300A, those 300 log columns are totaled and entered on the 300A.
The part that is often difficult to ascertain is the field asking for the total hours worked in a year for that location and the average number of employees for that location. Many accounting departments loath 300A season and pulling all those numbers, so it’s a good idea to engage with your accounting or payroll department early if you need their help.
It’s important to know each 300A needs to be signed by an executive at your company confirming it is true, accurate, and complete. That person is supposed to be the owner of a company or an officer of a corporation or the highest-ranking official. Even if you had zero entries on a 300 log for a particular location, you still need to produce a 300A. The 300A forms are to be posted at the workplace location, in an area accessible by all employees, from February 1st to April 30th.
How long do you have to keep all three of these forms? Five years.
And the 300 log and the Form 301 are supposed to be updated within 7 days of a recordable workplace injury or illness.
Earlier, we mentioned another deadline: March 2nd. Certain employers have to report their 300A information directly to OSHA in what OSHA calls the Injury Tracking Application. OSHA says in their own words, “Only a small fraction of establishments are required to electronically submit their 300A data to OSHA”. To find out if you are part of that small fraction, check out the injury tracking page to see if your industry type is listed.
Additionally, the BLS (Bureau of Labor Statistics) randomly selects employers and/or certain employer locations to submit their 300A forms to them. This is a government agency separate from OSHA – more on them in a bit.
If you are an employer who needs to submit your data to OSHA or BLS dozens or hundreds of times, the work can be made easier depending on the system you are using to maintain the logs and 300A forms.
How are these forms helpful to me as an employer?
OSHA is compelling you to do all of this work but is any of this useful to you? Yes, it can be.
You can use the data to:
- Calculate incidence rate (number of recordable injuries and illnesses occurring among a given number of full-time workers) over a given time period
- Calculate your total recordable case rate
- Calculate DART rate (Days Away Restricted Time) to compare:
- Year over year
- Location to location
- Your company to others
- Track and trend when injuries and illnesses are occurring
- Identify where you may need to make changes
- Support mitigation strategies
You’ll be able to find the formulas to the calculations on page 5 of this OSHA forms summary resource.
Why does OSHA need all this data?
Do you ever wonder why OSHA wants your data and what happens to it? It’s given to the U.S. Bureau of Labor Statistics or BLS and some of you are tapped on the shoulder by BLS to give your data directly to them. If that happens, BLS will send you a notice directly. The BLS then slices and dices the data 8-ways to Sunday – publishing various reports on injury and illness statistics in the United States. For example, we can learn the median number of days away from work in 2020 resulting from an injury or illness was 12 days or that there were 4,764 souls who lost their lives at work in 2020.
If you love data and are interested in how your industry compares to others like you, you can get lost for days on the BLS website. BLS also has a nifty calculator where you can enter 4 points of data from your 300A, select your type of industry or state, and the results show how you compare to others like you or in your region!
Yes, OSHA’s recordkeeping requirements can be cumbersome, however, they can be easier to manage if you know where to find resources, use modern systems to help manage them and use the data to advance your health and safety initiatives.
Now go refresh your coffee and get lost in the data!
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