The OSHA Recordkeeping Scramble
A new year is upon us, which means the start of the annual scramble to finalize your 2015 OSHA 300 logs and 300A form. So what is actually required per OSHA’s recordkeeping standard? In the simplest terms, there are three things that need to happen:
- Whenever a recordable incident occurs (meaning it required medical treatment, job restriction, days off work, etc.), the injury must be recorded on your OSHA 300 log within seven days.
- At the end of the year, each company is required to complete the OSHA 300A summary form. This is completed using the information from the 300 log.
- Then the complete OSHA 300A form must be posted (wherever employee notices are typically posted) from February 1-April 30. It’s important to remember that only the 300A summary form should be posted, as the 300 log contains personal injury information.
But how does that work for temporary staffing companies when one of their temporary employees is injured? OSHA’s recordkeeping standard states that whoever provides “day-to-day supervision” of the temporary employee is who must maintain the injury on their OSHA 300 log. In most cases, this will be the host employer. Even if the staffing company has an on-site supervisor, “day-to-day supervision” is defined as whoever specifies the “output, product or result” as well as the “means, methods and processes” to achieve them – meaning that unless the staffing company is determining what products are made each day and how, they’re likely not providing day-to-day supervision.
This doesn’t necessarily mean that staffing companies are off the hook though. Temporary staffing is not considered an exempt industry for OSHA recordkeeping purposes, so an OSHA 300 log still needs to be maintained for injuries that happen to staff employees. Even if there are no injuries for the year, a 300A summary form still needs to be completed and posted during the required timeframe.
There are also instances where the staffing company will agree to maintain the OSHA 300 logs for their employees as a service to their clients. If there’s an agreement in place that the temporary staffing company will maintain the 300 logs, the staffing company will likely be on the hook if they’re not maintaining the logs as required.
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