CONN-OSHA Answers Your Safety Questions: May 2022

05.10.2022
FAQ
HR & Safety

Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked safety questions from CBIA member companies.

Most of the responses from Catherine Zinsser, a CONN-OSHA occupational safety training specialist, will be on recordkeeping since that is the focus of most questions she fields.

But if you’d like to ask her a question on another topic, please email CBIA’s Phillip Montgomery.

He will treat all questions confidentially and never share any identifying company information with CONN-OSHA or anyone else.


Q: We have multiple locations, in Connecticut, Maine and New York. Are we required to maintain the OSHA recordkeeping forms at each of these locations?

A: Yes, you must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer. 

You may keep the records for an establishment at your headquarters or other central location if you can:

  • Transmit information about the injuries and illnesses from the establishment to the central location within seven calendar days of receiving information that a recordable injury or illness has occurred and;
  • Produce and send the records from the central location to the establishment within the time frames required by 1904.35 and 1904.40 when you are required to provide records to a government representative, employees, former employees or employee representatives.

Q: If an employee experienced a recordable hearing loss case, where would the employer record the case on the OSHA 300 Log?

A: Prior to 2004, employers should record work-related hearing loss cases according to the instructions included with the recordkeeping forms. 

If the loss is associated with an event, such as acoustic trauma (e.g., an explosion), it would be recorded as an injury with a check mark in column (M)(1).

If the loss is not an injury, it would be recorded as an illness, with a check mark in the ‘all other’ illness column. 

Beginning in January 2004, employers must record all hearing loss cases in the separate hearing loss column (M)(5).


Q: If an employee is let go from a job based on poor job performance and later comes back and says he was injured on the job, but there is no evidence an injury occurred, is this considered an OSHA recordable case?

A: If you determine that there was no work-related injury, you do not have to record the case. 

Under the OSHA recordkeeping system, the employer has the ultimate responsibility for making good-faith recordkeeping determinations regarding an injury and/or illness. 

Employers must decide if and how a particular case should be recorded and their decision must not be an arbitrary one.


For more information, contact CBIA’s Phillip Montgomery (860.244.1982).

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