CONN-OSHA Answers Your Safety Questions

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.

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Q: What is OSHA’s stand on an injury that occurs at work as a result of an employee being under the influence of illegal substances?

A: Being under the influence of an illegal substance is not a factor when determining recordability for OSHA recordkeeping purposes.

Q: May employers attach missing information to their accident investigation or workers’ compensation forms to make them an acceptable substitute form for the OSHA 301 for recordkeeping purposes?

A: Yes, the employer may use a workers’ compensation form or other form that does not contain all the required information, provided the form is supplemented to contain the missing information and the supplemented form is as readable and understandable as the OSHA 301 form and is completed using the same instructions as the OSHA 301 form.

Q: Our service utilizes volunteers as part of our workforce. How do I record an injury for a volunteer who does not receive any compensation and has been told to take three days off from work but has no regular scheduled shift or hours.

A: Only injuries to employees should be entered on the OSHA 300 log. 

Generally, unpaid volunteers are not considered employees under the OSH Act. 

If the volunteer is receiving some form of compensation (monetary or non-monetary) for services, then there may be an employer-employee relationship for the purposes of OSHA recordkeeping.

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For more information, contact CBIA’s Phillip Montgomery.