CONN-OSHA Answers Your Safety Questions: December 2020

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: Our company has a pet friendly policy and the dog of one employee bit another employee, causing him to miss two days of work because of the stitches. Is this recordable?

A: Yes, the injury is recordable. The dog bite is considered work related and recordable because the injured employee received medical treatment beyond first aid.

OSHA has consistently taken the position that insect bites or animal bites on premises are work related.

The case does not meet any of the work-related exceptions in OSHA regulations.

Even if this happened in the parking lot when the employee was on lunch break and it was a stray dog, it is still a recordable injury.

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Q: We plan on opening two small satellite facilities in the southern and western parts of the state. Can I centralize the Form 300 reporting or must records be kept for separate locations?

A: Yes, 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 this OSHA regulation, and this regulation when you are required to provide records to a government representative, employees, former employees or employee representative.

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Q: A significant portion of our workforce is now working remotely and never reports to our plant site. Do I need to send them a copy of Summary Form 300A to meet the posting requirement?

A:  No. You are only required to post the summary at the physical establishment linked to the log.

There are no additional requirements that you reach out to workers who do not physically report to the site.

If a worker requests access to the summary, you need to provide it as required by the rule.

You certainly are not prohibited from providing these workers a copy of the summary through additional means—such as mailing or emailing a copy directly to each worker if you choose.

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