CONN-OSHA Answers Your Safety Questions: January 2024

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: If an employee has days away from work that span one year to the next (e.g. out from December through March), do you go back and update the previous year’s log to reflect the total days out?

A: Yes. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred.

If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Q: If an employee sustains a work related injury in 2023 and doesn’t report it until 2024, which log should the information be recorded on? Should it be recorded on the 2023 or the 2024 form?

A: The Injury or illness should be recorded in the year that the incident actually occurred—in this case, 2023.

You can go back and modify the log for that year and retain it in the files according to the retention regulations.

Q: If I have no work related injuries or illnesses in a calendar year, do I still need to complete a form 300 log?

A: You do not need a completed Form 300. However even if your establishment did not have any OSHA recordable injuries or illnesses, you must still enter zeroes in the total columns on the OSHA form 300A and post the form from February through April.

---

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