Record It or Not?
Question: Right now, during this pandemic, in some locations, many employees of nonessential businesses are required to work from home. While working from home, what if an employee is injured or even worse, exposed to an infectious disease like COVID-19? Do you have to report that to OSHA?
Why are we talking about this right now? Because on January 31st, the OSHA 300A log is to be posted. What are OSHA logs? These are a set of three logs that keep track of some injuries and illnesses that happen on the job or at the workplace. Here’s a brief synopsis of the logs and what you do with them:
OSHA Form 301: The Injury and Illness Incident Report is the first of the three logs that should be filled out following a recordable incident. It is where specific information is recorded about a job-related injury or illness within seven days of an incident. It will contain personal information about the patient, so it is confidential. One form is to be filled out for each incident and/or each employee. The form is kept in a file and not released unless requested by the patient, their representative, or an OSHA representative.
OSHA Form 300: The Log of Work-Related Injuries and Illness is the form that is used to compile the totals from the 301 forms. This is best done after the end of the year but before January 31st as you will be entering the total ofhow many days of lost time or restricted duty were involved in each case. It will not contain any personal, confidential information other than an employee’s name, categorize the injury or illness, and total up the time as previously mentioned.
OSHA Form 300A: This form only has the totals from theForm 300. For work related injuries and illnesses that happened in 2020, the 300A log must be posted from February 1, 2020 to at least April 30, 2021. After April 30, the log must be maintained in a file for at least five years.
Here is a link to where you can find the forms. We recommend using the excel spreadsheet. It has built-in formulas that will populate numbers from one work sheet or form to the next one. https://www.osha.gov/recordkeeping/forms
What goes on these logs? Any workplace related injury or illness that you report to OSHA, which includes a fatality, the loss of a body member or disfigurement, and any hospitalization other than for observation. You also need to record other work-related injuries and illnesses that don’t have to be reported to OSHA, including:
- Any work-related injury or illness that results in time away from work (“lost work time”).
- Any work-related injury or illness that results in restricted work or transfer to another job.
- Any work-related injury or illness that includes loss of consciousness or treatment beyond first aid.
OSHA has defined what constitutes first aid. It’s a rather lengthy list, so we are linking it here for you: https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7. Scroll down to 1904.7(b)(5).
Why are we recording all this information on these forms or “logs” as OSHA calls them? For what purpose? Thereason is twofold. One, the Bureau of Labor Statistics (BLS) takes the reported and recorded information and keeps track of it. Two, you have the information written down in case an OSHA inspector asks for it. How does theinformation get relayed to the BLS? Through OSHA. You report what is on your OSHA 300A log through this link. https://www.osha.gov/injuryreporting/
Those of us in California, a state plan state, only have to report the data to OSHA if we have 250 employees or more, or if we have 20 – 250 employees and fall into certain industries. You can see if your workplace is required to report through this link: https://www.dir.ca.gov/dosh/calosha-updates/log300-reporting.html.
Whether you are in California or one of the other 49 states, the information must be transmitted to OSHA by March 2nd.
Now, back to our original question. What about those ofus who are currently working from home? Are we recorded on these forms? The answer is “yes.” And we follow the same recording criteria as if we were working at our business facility or site. OSHA uses the example ofpicking up a box of files while working at home and accidentally dropping on your foot. If the foot requires more than first aid, or you lose work time because of theinjury, it’s recordable. However, the key question is whether the task is work related or not. If you trip over your kids toys and injure yourself, that’s not work related.
3. Was the employee hospitalized for medical treatment? That would be a reportable and recordable event.
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