Four Events, One Week: What Goes on the 300 Log and What Goes to OSHA
Ridgeline Stamping runs a single 68-employee plant making HVAC brackets. The safety manager keeps the OSHA 300 log and has five events from one week in March. (1) A temporary worker supplied by Keystone Staffing lacerates his forearm on a deburring table; Ridgeline's shift supervisor assigns his work each day. He receives five sutures, returns the next morning on light duty with a 10-pound lifting limit that lasts 12 calendar days. (2) A press operator reports hand numbness; the clinic diagnoses work-related carpal tunnel syndrome and restricts repetitive gripping for 30 calendar days. (3) A shear operator sustains a traumatic fingertip amputation; he is treated and released from the emergency department the same day, with no admission. (4) A maintenance technician collapses while working near a heat-treat oven, receives intravenous fluids in the emergency department, and is admitted overnight. (5) A fifth worker has a small cut cleaned and bandaged on site and returns to work. The staffing agency's safety contact calls and says the temporary worker's case belongs only on the agency's log.
1. Which of these five events belong on Ridgeline's OSHA 300 log, and how should the day counts be entered for each recordable case?
Read the worked answer
Apply the 1904.7(b)(2) criteria to each event: death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury diagnosed by a physician or other licensed health care professional.
- Temporary worker: recordable. Sutures are medical treatment beyond first aid, and the 10-pound limit is restricted work. Count days this way (1904.7(b)(3)): begin with the day after the injury or the day work was restricted, count every calendar day the restriction applies including weekends and days he would not have worked, stop at 180. Twelve days go in column (5). If he had stayed home, column (4) days away would apply until his return.
- Carpal tunnel: recordable. It is a significant injury diagnosed by a clinician plus 30 days of restricted work, so enter 30 in column (5). This is not a privacy-concern case under 1904.7(b)(7), so his name stays on the log; if it were, enter the words privacy case instead.
- Fingertip amputation: recordable. Treatment beyond first aid, entered as an injury.
- Heat case: recordable. Drinking fluids for heat stress is first aid under 1904.7(b)(5)(i), but intravenous fluids are not on that list, so this is medical treatment.
- Bandaged cut: not recordable. First aid only.
Do not forget column (6) injury/illness type and the 300A annual summary, posted February 1 through April 30.
2. Which events must Ridgeline report to OSHA, under what deadline, and to whom? What mistake would the employer make by assuming a same-day discharge removes the reporting duty?
Read the worked answer
1904.39(b) sets two clocks: a work-related fatality must be reported within 8 hours; an in-patient hospitalization, an amputation, or the loss of an eye must be reported within 24 hours. Each clock starts when the employer learns of the event, not when it happened.
- Fingertip amputation: reportable within 24 hours as an amputation. OSHA treats traumatic loss of an external body part, including a fingertip that is not reattached, as an amputation for reporting purposes. The same-day discharge is irrelevant because the trigger is the amputation, not hospitalization.
- Overnight admission: reportable within 24 hours as an in-patient hospitalization. If the emergency department had merely observed him and sent him home, no report would be due, which is why the facts about admission matter.
Report by telephone to the nearest OSHA area office or the 24-hour number (1-800-321-OSHA), or through OSHA's online reporting option where accepted. Give the establishment name and address, time of the event, type of event, number of fatalities or hospitalizations, and a contact person. Filing the 300 entry is a separate obligation and does not satisfy 1904.39. Also flag the heat case: if the technician dies within 30 days, the 8-hour fatality clock applies immediately.
3. The staffing agency argues that only one employer records the temporary worker's injury. Evaluate that claim and explain how the case should be handled on both logs.
Read the worked answer
1904.31(a) requires an employer to record on its log the injuries and illnesses of employees it supervises day to day, and 1904.31(b) makes clear this includes workers who are not on the payroll, such as temporary workers supplied by a staffing agency. Because Ridgeline's shift supervisor assigns the temp's work every day, Ridgeline supervises him day to day and must record the case on its own 300.
The agency's claim is wrong in both directions. The staffing agency may also have a recording duty if it supervises the worker, and the case can legitimately appear on two separate logs belonging to two separate employers. That is not double counting; each log is that employer's own record of its own establishment, and each 300A summary counts only the cases on that employer's log.
The practical steps: Ridgeline enters the case and obtains the 301 detail from the agency (or completes its own 301), records the day count as it observes the restriction, and coordinates with the agency so the injury description matches. Both parties should agree in the contract on who notifies whom. Ridgeline cannot discharge its duty by pointing to the agency's log, and neither can it suppress its entry because the agency also records it.