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Test Your Record Keeping (Part 5) - Top Errors in Completing the OSHA Recordkeeping Forms.

Now that you have had some practice on what illnesses and injuries should be recorded on the OSHA recordkeeping logs, let's examine the most common errors we see when actually filling out the logs properly with that injury and illness information.

While the OSHA 300 log appears simple on its face, the one-page document asks for very specific information and demands precision in completing the forms accurately. We rarely review a form that is completed 100% correctly. Hopefully, by being aware of those common errors, you can avoid them when completing your own form.

The most common errors we see when reviewing OSHA 300 logs are:

  1. A lack of detail with regard to the description of the injury/event. Column (F) of the form requires that the employer include information (a) describing the injury or illness, (b) identifying the body part(s) affected, and (c) identifying the cause or object that directly injured or made the employee ill. While most employers write down the body part, they neglect to identify at least one, and sometimes both, of the other required elements. More often than not, they leave off the information about what caused the injury. We see a lot of entries such as "sprained knee" and "strained back" without an explanation as to how it happened.
  2. Failure to identify the precise body part when there is more than one. When there is a "mirror image" of a body part, the employer must identify whether it is the left or right side that was injured. If someone injures their ankle, for example, the entry should state "left ankle" or "right ankle." Employers often forget about less obvious body parts such as the eyes, ears, and fingers. Toes and fingers require an even more specific description such as "right index finger."
  3. Checking off more than one type of classification for a case in columns (G) through (J). The OSHA log only requires that the most serious result of the case be checked off in columns (G) through (H), and not all that apply. So, if an employee is out of work and then returns but remains on restriction, only the column for days away from work (H) should be checked, and not also job transfer or restriction (I). The employer should, however, write in the correct number of days the employee was away and the number of days on restriction in columns (K) and (L). As a double check, the page totals for the entire classification section (columns (G) through (J) should not exceed the total number of cases entered on the form.
  4. Incorrectly adding up the page totals under the classification of the case. The totals for columns (G) through (J) should always equal the number of total cases entered on the form (Column (A)). The same is true for the totals in columns (M)(1) through (5).
  5. Incorrectly identifying the type of injury or illness in column (M) or checking more than one type.
  6.  Failing to fill in a "0" on the job transfer or restriction column (K) and days away from work column (L) when there were no days away or transfer/restriction. These columns should not just be left blank.
  7. Failing to provide enough detail about the location of the injury in column (E). This column requires the employer to list the precise location to the extent possible. For example, "in the office" would not be acceptable, but "third floor break room" or "assembly section of plant" would be acceptable.
  8. Failing to fill in the correct establishment name on the form.
  9. Failing to fill in the year on the form (top right corner).

On the OSHA 300A Summary, the most common mistake is failure to date and sign the form. On occasion, the number of cases, day and injury type will not be correctly transferred over to the summary page from the 300 log. Employers can also be cited when a non-executive signs the form.

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