OSHA 300 Logs Reminder

The OSHA 300 Log is part of a federal requirement pertaining to safety in the workplace.  Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses, including work-related COVID-19 cases. (Certain low-risk industries are exempted.) Minor injuries requiring first aid only do not need to be recorded.

When Do I Need To Post?

The OSHA 300 Log must be posted every year by February 1st of the following year, listing all injuries from the previous year and must remain posted until April 30th

Where Do I Post the Log?

The log must be posted in a location where it is visible to all employees and where business or operations are conducted. 

What do I include in the log and when?

The log records all applicable injuries or illnesses that occur in the workplace, including COVID-19-related instances. 

How does OSHA define a recordable injury or illness?

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
  • There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

What about COVID-19-related instances?

The Occupational Safety and Health Administration (OSHA) recently issued new guidance on employers’ obligation to document COVID-19 cases in the workplace for OSHA recordkeeping purposes. Specifically, employers who are required to keep OSHA 300 logs are now required to record cases of COVID-19 (which OSHA considers a respiratory illness) on such logs if the employer determines that the employee’s COVID-19 illness is work-related. The new guidance went into effect on May 26, 2020.

When to record COVID-19 cases

Under the new guidance, a case of COVID-19 must be recorded by the employer if:

  • An employee has a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);
  • The case is work-related (i.e., an event or exposure in the work environment caused or contributed to the illness); and
  • The case meets one or more of the recording criteria set forth under general OSHA standards (i.e., the case results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness or significant injury or illness diagnosed by a physician or other licensed healthcare professional).

You can view the full updated guidance on COVID-19 Compliance here

How does OSHA define first aid?

  • Using 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);
  • Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
  • Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
  • Using hot or cold therapy;
  • Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
  • Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
  • Using eye patches;
  • Removing foreign bodies from the eye using only irrigation or a cotton swab;
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
  • Using finger guards;
  • Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
  • Drinking fluids for relief of heat stress.

Maintaining and Posting Records

The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.

Updated Electronic Submission of Records

The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you can provide the Agency your OSHA Form 300A information. The date by which certain employers are required to submit to OSHA the information from their completed Form 300A is March 2nd of the year after the calendar year covered by the form.

What about privacy protection and COVID-19?

The guidance further notes that if a COVID-19 case is recorded on the OSHA 300 log, the affected employee has the right to request that his or her name not be entered on the log for privacy reasons. Under such circumstances, the employer must comply with the employee’s request and enter the phrase “privacy case” instead. The employer must also maintain a separate, confidential list of privacy concern cases with case numbers and employee names to be provided to the government if requested.