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.

 Q: We are concerned about the passage of Connecticut's new marijuana law. If an employee is injured on the job and we later find out they were impaired, do we still record this incident? 

A: Yes. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.

Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in § 1904.5(b)(2) specifically applies.

There is no exception for alcohol or drug impairment under 1904.5(b)(2).

Q: Our firm does different things at different locations. Do I submit my information under the classification of the individual location or parent firm?

A: When the injury or illness occurs at one of your establishments, you must record the injury or illness on the OSHA 300 Log of the establishment at which the injury or illness occurred.

Each establishment of that enterprise is assigned a NAICS code, based on its own primary business activity.

Q: Our company has offices across the country. What is the minimum number of employees per site that would requires us to post a copy of the OSHA log/summary? Our number of employees per site range from two or three up to several hundred.

A: Each separate establishment in existence a year or more is to have its own OSHA 300 log regardless of the number of employees working at that establishment.

The partial exemption for size is based on the number of employees in the entire company.

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

Filed Under: Employment Law, Manufacturing, OSHA, Safety

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