OSHA Log and Reporting Decisions Before an Inspection
A general contractor with 85 employees builds commercial interiors. In February, a laborer employed by a staffing agency and supervised day-to-day by the general contractor cut his hand on a table saw; he received three stitches and returned to work the same day. In March, a carpenter fell from a scaffold, was hospitalized overnight for a concussion, and was placed on restricted duty for two weeks. In April, a worker reported wrist pain that developed over several weeks of repetitive work; a physician diagnosed tendonitis and recommended light duty. The company's OSHA 300 log has not been updated since December, and the 300A was posted on January 15. The safety manager is preparing for an OSHA inspection and wants to know what to fix.
1. Determine the recordability of each case and any reporting obligations.
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Analyze each case for work-relatedness, new case, and a recording criterion.
- February, table saw: three stitches are sutures, which are medical treatment beyond first aid, so the case is recordable even though he returned the same day. The host employer that supervises the worker day-to-day generally records the case; the staffing agency may also have obligations, so the two employers should coordinate to avoid double counting.
- March, scaffold fall: recordable. The concussion involved medical treatment, and the two-week restriction is restricted work; there may also be days away. An in-patient hospitalization must be reported to OSHA within 24 hours if it was formal admission for care or treatment. Record within seven calendar days.
- April, tendonitis: likely recordable if the physician recommended light duty, because that is restricted work; a prescription-strength medication would also trigger recording. If it was only nonprescription ibuprofen with no work restriction, it would not be recordable. The repetitive-work connection must be documented.
2. What is wrong with the 300A and log maintenance?
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The 300A posting date is wrong. The summary must be posted from February 1 through April 30, so posting on January 15 is premature and does not satisfy the requirement for the correct period. The log not being updated since December means February, March, and April cases are missing; recordable cases must be entered within seven calendar days of learning about them. The 300A must be certified by a company executive and must reflect the actual log totals.
Also check retention: the log and summary must be kept for five years and made available to employees and their representatives on request. If the establishment is covered by electronic submission requirements, verify the submission. Before the inspection, reconstruct the missing entries from medical records, incident reports, and payroll data, but do not backdate in a way that hides late entry. Correct the record and document the correction.
3. What should the safety manager do before and during the inspection?
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Before the inspection, audit at least the current and prior year logs against incident reports, clinic visits, and restricted-duty records. Identify privacy-concern cases and handle the name column correctly. Verify the 300A is posted and certified, and confirm reporting files for the hospitalization and any other reportable event. Brief supervisors on what the inspection will cover and instruct them to answer factually, not speculate.
During the inspection, provide the records requested, accompany the compliance officer, and take duplicate notes and photos. Do not argue recordability on the spot without the file. If a case was missed, acknowledge it and state the correction. After the inspection, fix the systemic causes: a monthly log reconciliation with HR and clinic data, a clear temporary-worker recording agreement with staffing agencies, and a calendar reminder for the February 1 posting and five-year retention.