OSHA Form 300A Compliance
Form 300A is the summary of work-related injuries and illnesses occurring at your facility during the previous year. Employers are required to post this information at their location from February 1 through April 30 of the following year.
Just like Tier II compliance, summaries are required for each individual plant or facility under your management. Separate logs and summaries should be maintained at each site.
One of the more recent developments, however, is that summary information must be submitted to OSHA through their online portal if your facility meets certain size and industry requirements. For more information regarding requirements for industry, you can use OSHA’s FAQ website here: https://www.osha.gov/injuryreporting .
The rule requiring establishments with over 250 employees to submit the entire 300 Log and not just the summary was amended and is no longer required; however, facilities must continue to maintain those records and are required to provide them to an inspector upon request.
So, how can Cornerstone help?
Our Incident Management program will not only help you accurately collect and maintain incident information, but it can also provide customization and control well beyond OSHA’s generic spreadsheets and manual collection. It will also keep backup archives so this information can never be lost.
All facilities are required to submit information through the OSHA Injury Tracking Application (ITA) website. Cornerstone can help by automatically generating files in “.csv” format to upload to the OSHA ITA program to save you time entering the summary data for every single facility. Even for a single facility, it is much more efficient to upload the csv file rather than manually entering the data.
In addition to proving a summary to comply with reporting requirements, the program will automatically generate the “.pdf” files necessary for display at the facility. Again, this is not a reporting requirement, but is required for compliance.
This is just a fraction of the benefits an incident management system can provide. Most importantly, it can help drive a healthier and safer workforce while also easily keeping you in compliance with electronic recordkeeping requirements.
Recent Posts
Incident Investigation and Injury/Illness Reporting Requires a Systematic Approach
No one wants to have workplace accidents, but when they happen it’s important to have an Incident Investigation and Injury/Illness Reporting Program in place. The program must include the procedures necessary to properly investigate the incident and determine the cause as well as how to prevent a recurrence. The following is a summary of the steps necessary to properly respond, investigate and record an incident to meet OSHA compliance.
Reporting the Incident
First and foremost, employees must immediately report all incidents and near misses to their supervisor who will then notify the person responsible for incident investigation and injury/illness reporting. Depending upon the type and severity of the incident, notification to OSHA may also be required.
Investigate the Scene
All incidents, regardless of severity or impact, need to be thoroughly investigated. The process must look beyond what happened to discover why it happened. This will allow for the identification and correction of shortcomings in the safety and health management programs. The principal incident investigators must go to the site of the incident to conduct the investigation. It is critical that the scene is preserved to prevent material evidence from being removed or altered. Using cones, tape, and/or other guards may be required. Facts must be carefully documented.
Collect Information
The principal incident investigators must collect information through interviews, review of documents, and other means. Using a checklist may help ensure that all information pertinent to the incident is collected. In addition, other sources of useful information may be sought out such as equipment manuals and training records.
Determining Root Cause of the Incident
The principal incident investigators must determine and document the underlying reasons the incident occurred and the corrective actions required to prevent future incidents. At a minimum, a determination must be made whether there are deficiencies in any area, and in doing so persistently ask the question “Why?” at least 5 times to probe the area in depth.
Corrective Actions
The investigation is not complete until corrective actions are implemented that address the root causes of the incident. Implementation entails program-level improvements and must be supported by senior management. It is important for the person(s) responsible for incident investigation and injury/illness reporting to review the root cause factors and corrective actions and forward the information to appropriate management personnel for follow-up and implementation. It is recommended for management personnel to(s be responsible for ensuring corrective actions are implemented.
Training
The person(s) responsible for incident investigation and injury/illness reporting must also provide training to management employees who are assigned duties under the program. The training must cover a review of the Incident Investigation and Injury/Illness Reporting Program, including all the information needed and steps involved in the process.
Records Required by OSHA
The person(s) responsible for incident investigation and injury/illness reporting must ensure all injury/illness records required by OSHA are completed and maintained. The company must record information about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. Significant work-related injuries and illnesses diagnosed by a physician or licensed health care professional must also be recorded. In addition, the company must record work-related injuries and illnesses that meet any of the specific recording criteria listed in 29 CFR 1904.8 through 1904.12.
OSHA recordkeeping and reporting requirements are extensive and necessitate a robust system for reporting and retaining records related to incident investigations. To ensure all the necessary information is investigated and reported properly, ask an expert for help when implementing an Incident Investigation and Injury/Illness Reporting Program.
Further Information
Cornerstone offers a structured software application for Incident Management which can be an invaluable tool to support incident prevention programs and facilitate the process of investigating and recording incidents. We also offer safety management programs and training to help prevent injuries and illnesses in the workplace. Learn more about Incident Management Systems.
David Blane is a Senior Health and Safety Specialist. He is a Certified Safety Professional by the Board of Safety Professionals. He currently provides health and safety compliance auditing, program development, training, and industrial hygiene monitoring to Cornerstone’s industrial and construction sector clients. Blane formerly served as an OSHA compliance inspector.
Recent Posts
Using Leading Indicators to Prevent Workplace Injuries
By Joshua Sampia All companies have an obligation to create a safe work environment that allows their employees to do their jobs with minimal risk of injury. Most business understand their obligation to report accidents and illnesses to government agencies at the federal, state, and local level. What if you could use modern technology and trends to not only create a safer work environment but also prevent injuries from ever happening? This would save you time and money from completing reports, medical billing, and insurance claims, as well as reduce lost work time hours.
What are leading indicators?
Leading indicators are data points that can help predict future events and trends. This is where having a proactive safety culture comes into play. Leading indicators can be used to assess workplace culture in order to develop safety plans to minimize risk and increase productivity. OSHA defines leading indicators as “proactive and preventive measures that can shed light about the effectiveness of safety and health activities and reveal potential problems in a safety and health program.” The cost of worker’s compensation claims can range from thousands to hundreds of thousands of dollars depending on the nature of the incident. Having a program in place that can help prevent even one of those claims will automatically pay for itself. There also are many other intangible benefits like reduced costs for worker’s compensation insurance or a reduction in the number of fines. As the saying goes, an ounce of prevention is worth a pound of cure.
Set Goals for Leading Indicators
Most companies have goals set for lagging indicators, such as a threshold for lost work time or number of injuries; however, your organization should also set goals for leading indicators, such as:
Attendance Rates
Safety Observations
Risk Assessments
Preventative Measures and Maintenance
The key to any good program is setting, identifying, and reaching quantifiable goals. For example, we work with a company that had historically relied on lagging indicators such as types of injuries, location, and work task to track injuries. Our team worked with them to implement a more observational approach focused on minimizing future occurrences. They formulated daily observation checklists of employees to determine if they were performing their tasks in an efficient and safe manner. That daily observation data was then aggregated and analyzed develop better safety and training programs. The change has helped reduce the number of injuries and accidents. Incidentally, productivity has also increased. Implementing this kind of process does not have to be a time-consuming process. The daily observations are short checklists of yes or no type questions that take approximately two minutes each day to complete. The checklist can be completed on mobile devices which most staff are currently using in their work tasks. The company also can share observations across multiple departments and shift supervisors to create a network of data for the entire business.
Technology and Software for Worker Safety
There are other examples of using modern data technology to help. Tracking employee training is a great way to ensure a good safety environment. Making sure employees are well-trained and that training is up to date is crucial to safety success. Another important aspect is that you must have a robust program in place to capture and analyze the data. A good system will:
let you easily capture all this information through multiple devices and portals
let you report the data back into multiple formats and reports
have a great dashboard to see a visual representation of the data
improve accountability
It is also critical to have traceability so it is clear who entered what data and when. This is extremely important when it comes to having a chain of evidence.
How can Cornerstone Help?
Cornerstone’s Incident Management and Training Tracking systems can capture all of this information as well a provide data reporting, visual representation, and more. Our applications have highly customizable systems that can adapt to literally any industry including automotive, manufacturing, medical, industrial as well as retail and warehousing. Each system is configured to each company’s specifications and requirements. This can also be accomplished at a cost-effective price point, especially when compared to the cost of having one accident on record. Contact us for details on how Cornerstone can help your facility establish an effective safety program using leading indicators and our industry-leading software systems.
Joshua Sampia is the Director of Product Development. He is responsible for the applications development team at Cornerstone, ranging from web based and mobile applications to device management for safety and environmental compliance and applicability.