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Top Ten OSHA 300 Questions

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1.    When do the OSHA incident reports (301) and logs (300) need to be filled in?

You must fill in the OSHA incident report and log within 7 days of a recordable incident.  It is recommended to start a new log started at the beginning of each year regardless if you had any incidents.

 

2.    Can you use your own reporting documents instead of the OSHA 301?

You can use your own documentation but it must capture all the information that is on the OSHA 301A.  I would suggest, though it may be redundant, to fill in the OSHA 301A in addition to your own documentation.

 

3.    Does Approach Management Services provide the logs and summary?

Every month, Approach Management Services provides a list of workers’ compensation claims, however, not all workers’ compensation claims are OSHA recordable and there may be recordables that are not workers’ compensation claims.

Best practice is to review the Approach monthly report and use it as a comparison only. Your company must have the 301 and OSHA log filled out within seven days of the injury or your company could be cited a penalty.

 

4.    Should I report all accidents as recordable to make sure I cover my bases?

No, you should only record those injuries/illnesses that fall under the OSHA record-keeping requirements.  You can report the injury/illness as NR (Non-Recordable), however, accuracy is important and over reporting negatively affects the industry average.

 

5.    When should I post my summary?

The OSHA 300A must be posted February 1st thru April 30th where employees will see this information such as on your required postings bulletin board.

 

6.    How do I calculate my DART and Incident rate?

The DART Rate is calculated by adding up the number of incidents that had one or more Lost Days, one or more Restricted Days or that resulted in an employee transferring to a different job within the company, and multiplying that number by 200,000, then dividing that number by the number of employee labor hours at the company.

       Total Number of DART incidents x 200,000

DART Rate = —————————————————–

       Number of Employee Labor Hours Worked

 

The OSHA Recordable Incident Rate (or Incident Rate) is calculated by multiplying the number of recordable cases by 200,000, and then dividing that number by the number of labor hours at the company.

 

          Number of OSHA Recordable Cases X 200,000

Incident Rate = ———————————————————–

Number of Employee labor hours worked

 

For easy computing, use the Incidence Rate Calculator: https://data.bls.gov/iirc/.

For more calculation resources visit: http://bit.ly/1PwHSrA

 

 

7.    When will OSHA electronic filing become a requirement? And will it apply to me?

Currently, Washington State DOSH has not adopted the federal electronic filing requirement. The requirement only applies to those who are under the federal jurisdiction such as a Military installation or workplace falls under Fed OSHA.  The federal requirement is as follows,

 

“The new reporting requirements will be phased in over two years:

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.”

 

8.     I have several locations where our company employees work, does each location require its own OSHA record-keeping documents?

If the answer is “yes” to any of these questions, you’ll need separate OSHA record-keeping documents:

  • Has the location been established greater than 1 year?
  • Does the location have 11 or more employees?
  • Are the locations a certain distance away such as across town or in another state?

 

9.    Can’t I just combine all of the establishments and make them as one? 

Generally, no.  The record-keeping requirements require you to separate them out.  If you have multiple smaller locations that last less than a year, you can combine the smaller locations into one establishment.

 

10. Where can I go to get information on common questions and interpretations on OSHA record-keeping resources?

OSHA has many resources such as letters of interpretation, LNI- DOSH has consultants you can contact and will provide you answers to specific questions and you can certainly call our safety team who is knowledgeable with the OSHA record-keeping requirement.

 

Visit:

OSHA – Standard Interpretations Website

LNI-DOSH – Record Keeping & Recording Website