The Back Injury That Grew: Recordability, Temporary Workers, and the Annual Summary
Ridgeway Metalworks stamps brackets in a 65-employee plant. On Tuesday, September 8, press operator Marcus reports mid-back pain after manually lifting a 60-pound steel billet. The plant nurse gives him ice and over-the-counter ibuprofen, and he finishes the shift at full duty. On Saturday, September 12, he sees a physician, who prescribes physical therapy and writes "no lifting over 20 pounds" for 15 calendar days; Marcus works light duty from September 12 through September 26. It is his first back injury. In the same week, a worker supplied by a staffing agency amputates the tip of his left index finger on a shear; the plant's shift supervisor directs that worker's tasks every day. The company has never kept an OSHA 300 log, and the plant manager asks you what must be done.
1. Is Marcus's case recordable, and exactly how should it appear on the OSHA 300 log? Walk through each recordability test, including how to count the days, and explain what would change if the physician had instead kept him off work for two days before the light-duty period.
Read the worked answer
Recordable - on two independent grounds.
- Work-relatedness (1904.5): the injury arose out of an event in the work environment (manually lifting a billet as part of his job), and it does not fit any of the listed exceptions (no voluntary non-work activity, no personal grooming, no self-medication on the employer's premises).
- New case (1904.6): no prior recorded injury to the same body part; it is a new case.
- Medical treatment beyond first aid (1904.7(b)(5)): the physician's prescription and physical therapy are medical treatment. Therapy is not on the first-aid list; the recordkeeping rules expressly treat physical therapy and chiropractic treatment as medical treatment.
- Restricted work (1904.7(b)(4)): the 20-pound lifting restriction is a restriction on his normal duties, which is a separate recordable criterion.
Log entry:
- Check the injury column; classify the case as restricted work/transfer (not days away).
- Column (4) days away = blank - he never missed a scheduled day.
- Column (5) restricted/transfer days = 15 (Sept 12–26 are counted as calendar days, not just scheduled workdays, and the count stops at 180 days).
- Enter the case within 7 calendar days of receiving information that it is recordable (1904.29(b)(3)).
If he had been off work two days first: the case becomes a days-away case. Days away go in column (4) only; column (5) stays blank for those days, because the form does not double-count. The case classification box changes to "days away," and any restricted days after his return are not added to column (4) once he is back at work.
2. The staffing-agency worker's fingertip amputation: whose log does it go on, and what must the plant do and by when outside of the log?
Read the worked answer
Log responsibility (1904.31). Recordability follows day-to-day supervision, not the payroll. Because the plant's shift supervisor directs this worker's tasks every day, the plant is a host employer and must record the case on its own 300 log. The staffing agency must also record it if it independently supervises the worker. Both logs may therefore carry the same case; that is expected, not an error.
Reporting (1904.39). A fingertip amputation is an amputation for reporting purposes - the definition covers traumatic loss of a limb or other external body part, expressly including fingertips, whether or not bone is involved. The plant must report the event to OSHA by telephone or through the online reporting form within 24 hours of learning of it. (Contrast: a fatality is 8 hours; an in-patient hospitalization for treatment, or loss of an eye, is 24 hours.) Do not wait for the 7-day log entry to make this report - the 24-hour clock runs from when the employer learns of the event.
The case is also entered on the 300 within 7 calendar days, and a days-away/restricted count is added later as the worker's status becomes known.
3. The plant manager plans to post the completed OSHA 300A on February 15, signed by the safety coordinator. Is anything wrong with that plan?
Read the worked answer
Timing is fine; the signature is not.
- The 300A annual summary must be completed from the log and posted from February 1 through April 30 of the following year (1904.32(b)(6)), so February 15 satisfies the posting window.
- The summary must be certified by an executive of the company - the highest-ranking company official at the establishment, or that person's direct supervisor if the top official is not physically present at the site (1904.32(b)(4)). A safety coordinator is normally not an executive, so a coordinator's signature would not satisfy the certification requirement.
- The summary covers only the prior calendar year and must reflect the log as it stood; if the log is updated later, the summary is updated too.
- Retention: the 300 log, 300A, and 301 incident reports are kept for 5 years following the end of the calendar year they cover (1904.33), and the 301 or equivalent is completed within 7 calendar days of learning of the case.
- Also flag that the company had no log at all until now - recordable cases from the current year must be reconstructed from injury reports and added within the 7-day rule as they are identified.