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OSHA 300 Record keeping

 SUPER BOWL SUNDAY – PASS THE ONION DIP AND POST YOUR OSHA 300 LOG

There is really no interesting way to say this so we’re just going to have to throw caution to the wind and blurt out that it’s February and time for employers to post their OSHA 300 Logs.  We at GCG were on pins and needles as the Academy Award nominations were revealed, and we were saddened to find that our newly released Webinar entitled “OSHA 300 Log Recordkeeping – Breathing Lessons in Tedium!”  was not listed in any category.  We are certain you will agree that the Academy just overlooked some great filmmaking by our great staff Elsie Tai and Joel Paradee, so we urge you to check out our Webinar on YouTube, available at http://www.youtube.com/watch?v=9QoIR7ImA3g.  No sign-in is necessary.  Just click the link, watch, listen and learn (please note this link will not come up on a YouTube search, as it is not “public” but rather “unlisted”).  In the event you don’t have time to view our production at this moment, we’ve printed up the basics for you.

Privately scheduled live-webinar sessions of this topic is available to our clients. Please contact Elsie Tai at elsie.tai@gcgriskmanagement.com if you would like to schedule a live session at your convenience for your staff.

What to Post – Don’t wait for Presidents Day!  February is OSHA posting time, and employers are required to fulfill the OSHA requirement and post the OSHA 300A Summary of the OSHA 300 Record of Injuries & Illnesses Recordkeeping Log for the past year (2012).  This posting must be done for the period February 1st  through April 30th inclusive.  The posting must be in an area accessible to all employees.

What NOT to Post – Remember DO NOT POST THE OSHA 300 LOG itself. (Frankly we think OSHA’s choices in form-naming is boring so we have taken some liberties).  This would publicize employee health information, violating basic health information privacy laws, including HIPAA (This would be a big no-no!).  Instead, the OSHA 300A Summary will require tallies, rates and an account of each category/column representing different case types.  There are two major categories of note:

  •     Total Number of Recordable Cases:  These involve all workplace incidents which require “medical treatment” beyond OSHA’s strict definition of “First Aid”.  OSHA’s definition of “First Aid” is NOT the same as that which you may use for non-reportable Workers’ Compensation claims.  As a result, if you routinely pay out-of-pocket for Workers’ Compensation First Aid Cases, BEWARE, OSHA’s definition of First Aid is far more conservative.  There may be First Aid cases which are in fact OSHA reportable, but which you have considered First Aid under your Workers’ Compensation program.
  •     Total Number of cases involving Days Away from Work (DART):  These include Loss of Time, Restricted Motion or Job Transfers.

What You’ll Need – Two Aspirin and a high school student who has studied Algebra.  Seriously, you will need to locate your Actual hours Worked by your employees in 2012 in order to calculate the rates for both categories of Total Recordable Cases (i.e. both categories above).  Be sure to include overtime (at time and a half rates), but not reduced pay, double-time or triple-time.  Count only actual hours worked.  You need to ensure you have an OSHA 301 or equivalent Incident/Accident Reporting Form for each case entry, as well as all other attending documents related to the reporting of each case.

If you have had a needlestick injury (OUCH!), you should also be keeping a Sharps Injury Log.  Finally, you should be keeping a Privacy Log (SHUSH!), if you have had any of the following:  needlestick incidents, bloodborne exposure incidents, sexual assaults, episodes of mental illness, HIV/Hepatitis/TB Infection, or anything an employee can reasonably ascertain to be a “privacy case”.

Thank goodness the internet (invented by former Vice-President Al Gore) because it makes it so much easier to save on printing and mailing costs, as well as saving a few trees.  For the Comprehensive 12-page OSHA Recordkeeping Guide which includes the OSHA 300 Log, the OSHA 300A Summary, and the OSHA 301 Log and instructions for all forms, go to http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf.

For a sample Sharps Injury Log or Privacy Log, sign in to our website at http://www.gcgriskmanagement.com and click on “Resource Library” and scroll down to “OSHA Recordkeeping or you may go to http://www.gcgriskmanagement.com/safety-resources/osha-recordkeeping once you are signed in to our website.  If you have not yet obtained a username and password in order to access the private Resource Library available only to GCG clients, please contact Angela Goff at angela.goff@gcgriskmanagement.com or call her at 800-638-8048 or 518-370-3303, ext. 8811.

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