“The U.S. Department of Labor’s Occupational Safety and Health Administration has cited the Lowe’s Home Centers Inc. regional distribution center in Rockford with $182,000 in proposed penalties for failure to document and report employee injuries and illnesses, as required by OSHA safety and health regulations.” That got your attention didn’t it? There should be no doubt about it, OSHA takes record keeping very seriously. Remember, it’s not about the paperwork itself, it's about the information on the paperwork. OSHA doesn’t have an army of compliance officers to constantly check in on every employer so they must rely on the employers themselves to self-report on injuries and illnesses.
To OSHA the lack of proper paperwork demonstrates a lack of respect for safety and raises reasonable doubts as to the employers commitment to safety. So do yourself and your employees a favor and keep up on your record keeping requirements.
According to OSHA 1904.32(b)(5) You must post a copy of the annual summary (OSHA 300-A Log) in each establishment in a conspicuous place or places where notices to employees are customarily posted. You must ensure that the posted annual summary is not altered, defaced or covered by other material. Everyone knows that…right?
Did you also know that the OSHA 300 Log must be certified as accurate by a company executive? Did you know that most safety managers, supervisors, directors, and/or coordinators do NOT qualify as an executive?
According to the OSHA, The company executive who certifies the log must be one of the following persons:
- An owner of the company (only if the company is a sole proprietorship or partnership);
- An officer of the corporation;
- The highest ranking company official working at the establishment; or
- The immediate supervisor of the highest ranking company official working at the establishment.
If as a safety manager, director, or supervisor you meet one or more of these definitions, then I congratulate you on a career well done! But for the rest of us, we need to make sure that a company executive certifies the OSHA 300 log. The company executive must certify that they have examined the OSHA 300 Log and that they reasonably believe that the annual summary is correct and complete.
When do I have to post the annual summary?
Employers must post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30.
Who Must Maintain the OSHA 300 Log?
All employers with 11 or more employees in the selected industries, as determined by their SIC and/or NAICS classification (e.g., Agriculture, Oil and Gas, Manufacturing, Construction, Transportation, General Merchandise Stores, Hospitality, and Health Services), must keep injury and illness records.
Some employers are normally exempt for these record-keeping requirements, such as Retail trade, Financial, Banking, Insurance and Real Estate sectors.
Employers who operate establishments that are required by the rule to keep injury and illness records are required to complete three forms: the OSHA 300 Log of Work-Related Injuries and Illnesses, the annual OSHA 300A Summary of Work-Related Injuries and Illnesses, and the OSHA 301 Injury and Illness Incident Report.
Employers are also required to keep separate 300 Logs for each establishment that they operate that is expected to be in operation for one year or longer. The Log must include injuries and illnesses to employees on the employer’s payroll as well as injuries and illnesses of other employees the employer supervises on a day-to-day basis, such as temporary workers or contractor employees who are subject to daily supervision by the employer.