It’s that time of the year again where we have just posted our 300 logs from the previous year (Or you should have!). Remember that your annual summary is to be posted by February 1 capturing the previous year’s data and is to remain posted until April 1.
In reviewing logs year after year for clients, the most common theme we see is recording of events that do not meet the requirement for placement on a 300 log. Now, that doesn’t mean you do not want to know about the incidents that are occurring in your workplace, but we need to delineate between “Reportable” and “Recordable”. As a company you want to know about all incidents that occur, including near misses, which we can define as “Reportable” but not all of these may be “Recordable”.
OSHA covers what is a recordable event under 29 CFR 1904 OSHA’s Injury and Illness Recordkeeping Rule. Basic requirements are Death, Days away from work, Restricted work or transfer to another job, Medical treatment beyond first aid, Loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional.
Where we see the most over recording is when it comes to incidents that involve some sort of contusion or are classified as musculoskeletal disorders (MSDs). If an employee is treated with basic first aid, defined in 1904.7(b)(5)(ii), and returns to work, then the event is not recordable. Many of the questions you may have regrading if an event is recordable are covered under 1904.7 and within the standard interpretations for each section.
In the end, the more events that land on your log, the higher your overall incident rate is going to be. This could in turn influence your insurance premiums or workers compensations rates. A good practice is to get a second opinion if you think an event may not meet the requirement or having a third party like URS Safety manage your logs can ensure compliance with built-in savings.