OSHA 300 Training One Page Every supervisor and manager should know who keeps the OSHA 300 log and what is required to document an entry. Every employee should receive awareness training about how entries are documented and what is looked for during an audit. Required Documentation An OSHA 300 log is needed for every facility your company has. Note that multiple buildings that are located at one site, have common management and maintain one set of records are considered a single establishment, and thus require only one 300 log. For multiple business establishments located at different sites, however, a separate OSHA 300 log is required for each establishment that is expected to be in operation for one year or longer (see 29 CFR 1904.30(a)). You can find all of the training materials, as well as the logs in Excel spreadsheet format, on the OSHA website (www.osha.gov). I highly recommend electronic record keeping rather than maintaining paper files. All of the 29 CFR 1904 rules and the record-keeping manual may also be found on the OSHA website. All first aid incidents and treatments are defined in the rule and illustrated in training programs. Following are the rare exemptions from OSHA 300 record keeping: • 29 CFR 1904.1(a)(1), which reads, “If your company had ten (10) or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the BLS informs you in writing that you must keep records under § 1904.41 or § 1904.42. …” • 29 CFR 1904.2(b)(1), which reads, “Does the partial industry classification exemption apply only to business establishments in the retail, services, finance, insurance or real estate industries (SICs 52-89)? Recording Criteria Record ability is spelled out in 29 CFR 1904.4, “Recording criteria,” which states that employers required to do so must keep records of each fatality, injury and illness that is work-related, a new case, and meets one or more of the criteria contained in sections 1904.7 through 1904.11. First Aid or Medical Attention? There is room for error in simply defining an incident and determining if it needs to be recorded. For instance, the first example of first aid found at 29 CFR 1904.7(b)(5)(ii)(A) is “[u]sing a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes) …” The Work Environment In 29 CFR 1904.5(b)(1), the work environment is defined as “the establishment and other locations where one or more employees are working or are present as a condition of their employment. ”If employees are representing the interests of their company on company property or a customer’s premises, they are considered to be in the work environment. Determination of Work-Related Events If a significant event or incident occurs during the course of work by an employee representing the interests of the company, it is work-related. It is not considered work-related if the event happens after normal business hours on personal business in the work environment, or if the employee is present in the work environment as a part of the general public. Pre-Existing Conditions The topic of pre-existing conditions tends to cause confusion. If an aggravation of a pre-existing condition occurs on the job during normal work hours while the employee is representing the employer, it must be recorded. OSHA 29 CFR 1904.5(b)(4) states that a pre-existing injury or illness has been significantly aggravated when an event or exposure in the work environment results in any of the following, which otherwise would not have occurred: • Death • Loss of consciousness • Days away, days restricted or days of job transfer • Medical treatment Days Away and Restricted Day Cases The number of days that must be recorded on the OSHA log shall be counted as to the opinion of the LHCP. The total number of days should be calendar days, not scheduled workdays. Days off, vacation days and sick days shall be counted. Employers must abide with the opinion of the LHCP. Even if the employee is no longer employed, the restricted days remain the same. Lastly, remember the record-keeping rule requires all businesses to keep the current year’s logs and supporting documents in addition to the last five years of all logs and supporting documents. All documents must be presented to auditors within four business hours of a request. Also, the OSHA 300 annual summary should be posted between February 1 and April 30 on a bulletin board in each facility.
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