CONN-OSHA Answers Your Safety Questions: April 2021

Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked 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’s 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.

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Q: My manufacturing company has three branches in the state with 10 employees at one facility, 12 workers at another, and 15 employees at the third. Because the total number of employees is more than 20, do I need to file the Form 300A, or am I exempted since no branch has more than 20 employees?

A: The OSHA law requires most employers with 10 or more full-time employees keep a yearly log of all work-related injuries and illnesses known as the OSHA 300 log. A summary of work-related injury and illnesses, the Form 300A must then be posted in the establishment, in a noticeable place from Feb. 1 to April 30.

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Q: If a student or intern who is part of a formal school program is injured, would I record the injury if it meets the requirements?

A: The Occupational Safety and Health Act of 1970 extends only to employees of an organization. There must be an employer-employee relationship. Students volunteering are not covered by OSHA regulations.

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Q: If an employer were to require, or just make available, the COVID vaccination to employees and an employee got ill, causing an absence or hospitalization, would OSHA recordkeeping standards apply? Would it matter if the vaccine was administered on site or off or during work hours especially if it is not a company requirement?

A: There are exceptions to the final rules “presumption of work relatedness” for injuries and illnesses. This section of OSHA’s final rule contains eight exceptions to the work environment presumption that are intended to exclude injuries and illnesses that occur or manifest in the work environment. One of these exemptions states that injuries and illnesses will not be considered work-related if they result solely from voluntary participation in a wellness program.

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