Checking It Once, Checking It Twice . . . Another Reason to Ensure OSHA 300 Logs Are Accurate

By Frank Marino, CSP for CRCA. 

Accurately maintaining your OSHA 300 log is a vital component to an effective health & safety program.

Keeping track of the injuries that occur at your company is a great way to determine where additional training might be needed, or new equipment required, or even as an indication of how your overall program is performing. In addition, the OSHA 300 logs are documents that are typically requested during an OSHA inspection. Fail to have the logs completed, and you could be opening yourself to additional citations and fines. But now I’ve got another reason to keep accurate OSHA logs, and I stress the word ACCURATE . . . OSHA is reviving the Site-Specific Targeting Program (SST). 

In an agency press release on October 16, 2018 OSHA announced it will be using the initial set of data collected from its electronic recordkeeping rule to identify workplaces with high injury and illness rates. The SST program directs OSHA enforcement resources to “high injury rate establishments” based on 2016 data from submitted Form 300A as well as those establishments who failed to submit any data at all (Safety&Health, 2018).

This is not a new program by any means, just one that OSHA is now reviving. Intended to be an annual program, SST was discontinued in 2014 after OSHA wound down its Data Initiative. The initiative, which started in 1995, was a collection of injury and illness data from approximately 80,000 organizations in “selected high-hazard industries” (Safety&Health, 2018). 

However, in 2016, OSHA improved tracking of workplace injuries and illnesses. The final rule required establishments with 250 or more employees and those with 20 to 249 employees in certain high hazard industries (which includes roofing) to electronically to submit data from Forms 300, 300A and 301 (Safety&Health, 2018). Although OSHA has recently proposed rolling back the rule to require only the Form 300 A, the data on all 3 forms collected in 2016 is available for their use. Although construction sites are exempt from this program, OSHA does include contractor companies with injury rates they feel exceed the industry.

It’s not uncommon for employers to “over-report” on their OSHA 300 logs. That is, to put every single injury that takes place in their organization, even if all of those injuries DO NOT meet the definition of an “OSHA recordable injury”. The problem with doing this is now OSHA will be using that over-reporting against you. That is why it is so important that OSHA 300 and 300A forms are filled out properly and accurately. Be sure to always have your company safety director review your OSHA 300 and 300A logs before they are submitted. As a reminder, OSHA 300A forms need to be completed and posted in your workplace on February 1, 2019 and electronically submitted on March 2, 2019. 

References: Safety & Health Magazine, December 2018 

Frank Marino is Vice President at Safety Check Inc., a safety consulting firm in the Chicago area and CRCA Associate Member. Marino has extensive experience in roofing safety. He can be reached at fmarino@ safetycheckinc.com. 

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Source: CRCA