Posted on / Updated on / in Blog & OSHA /

Our last post – A Simple Guide to OSHA 300, should have served as a bit of a kick in the pants to those struggling with OSHA 300 record keeping.  Hopefully this helped to clear the air of some confusion and things are back on track.  If you haven’t had a chance to read it yet, check it out to make sure you’re doing everything you need to be doing.  This post should help to clear up the rest.

In the previous post we told you what injuries are considered to be work-related. This post will help clarify what injuries are NOT work-related (if you have concerns after reading, please Contact Us for clarification), which is a question we get quite often in terms of OSHA filing.

So here is a list of items that are NOT considered medical treatments and are NOT recordable:

  • visits to a doctor or health care professional solely for observation or counseling
  • diagnostic procedures, including administering prescription medications that are used solely for diagnostic purposes; and any procedure that can be labeled first aid.
    • using non-prescription medications at nonprescription strength;
    • administering tetanus immunizations;
    • cleaning, flushing, or soaking wounds on the skin surface;
    • using wound coverings, such as bandages, BandAids™, gauze pads, etc., or using SteriStrips™ or butterfly bandages.
    • using hot or cold therapy;
    • using any totally non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.;
    • using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or back boards).
    • drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters;
    • using eye patches;
    • using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye;
    • using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from areas other than the eye;
    • using finger guards;
    • using massages;
    • drinking fluids to relieve heat stress

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IMPORTANT: Did you know that if you are supervising the work of temporary workers and contract workers, you have to record injuries and illnesses just the same as any other worker on your payroll? If you have hired temporary workers through a temp agency and you are supervising their work, they must be listed on your OSHA 300, regardless of whose workers’ compensation insurance covers them.

If the contractor’s employee is under the day-to-day supervision of the contractor, the contractor is responsible for recording the injury or illness. If you supervise the contracted employee’s work on a day-to-day basis, you must record the injury or illness. This is very important to proper filing.

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What data goes on the summary?

The summary log is fairly self-explanatory. You enter the individual’s name, specifics regarding the injury, whether there was lost or restricted time, etc.  When you are entering the data, it’s important to be thorough and concise.  However, one thing to consider that many individuals often neglect is that you do have the right, and the obligation, to omit employee names if the injury is of a sensitive nature.

For instance, if the injury involves an intimate body part, the reproductive system, sexual assault, pregnancy, HIV, needlestick infections, contagious disease, or mental illness, you can and should omit the individual’s name and instead list it as a “private case”.

Also, don’t forget to complete all of the company specific data, including the employee averages and hour totals for the year.

What if the data for the injury changes?

If the outcome or extent of an injury or illness changes after you have recorded the case, simply draw a line through the original entry. Then write the new entry where it belongs. Remember, you need to record themost serious outcome for each case, but you only need one entry for each case.

The reports are done.  Now what?

This form must be posted every year from February 1 to April 30.

The summary must be reviewed and certified by a company executive –  such as the owner, an officer , or the highest ranking company official at that site. You do not have to send the forms to OSHA unless OSHA has requested you to do so.

You must keep OSHA log and summary recordkeeping forms for five years following the year the year to which they pertain.

Now, where can you get these forms?

The easiest answer yet. OSHA’s website (http://www.osha.gov/recordkeeping/RKforms.html) provides these forms in both a PDF printable version and in an Excel spreadsheet.  With the spreadsheet, you really have no good excuse to not get yours posted quickly (and neatly!).

So if you’re behind follow the guidelines in these two posts and get this nagging task off of your shoulders. Believe me,you’ll sleep a lot better at night knowing it’s under control.

OSHA 300 filing can be a tedious task. If you need assistance classifying your injuries give us a call before filing time comes any closer. We’ll make sure you are doing things correctly.

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about the author: Amy Letke

Amy Newbanks Letke, SPHR, GPHR, is the Founder of Integrity HR, Inc. Amy provides workplace solutions to improve performance, reduce liability and increase profits. She is passionate about helping other entrepreneurs and business owners achieve success.