How Long Do You Have to Produce OSHA 300 logs?
Scenario: You are the safety manager of an establishment on the east coast in the Eastern Time zone. All your OSHA 300 logs and records are maintained at your corporate headquarters in California. On Tuesday morning at 7:00 AM (your plant starting time) sharp, an OSHA inspector appears at your facility door step and promptly commences an OSHA inspection. Very early in the opening conference, the inspector asks you to produce OSHA 300 logs for his review. You explain these logs are maintained at your corporate office in California and their work hours are 9:00 to 5:00 Pacific Time. It will be noon time at your plant before you can even get anyone at the corporate office to begin the process of responding to this inspector’s request.
The Inspector gets frustrated and tells you this is not acceptable. It is necessary for you to produce OSHA 300 logs upon his request. He needs to see them now or you are subject to an OSHA citation.
Question: Is the inspector correct in his belief that you must produce OSHA logs immediately?
Answer: The OSHA recordkeeping standard 1904.40(a) states the following: When an authorized government representative asks for the records you keep under Part 1904, you must provide copies of the records within four (4) business hours.
However if you read further: 1904.40(b)(2) states that OSHA will consider your response to be timely if you give the records to the government representative within four (4) business hours of the request. If you maintain the records at a location in a different time zone, you may use the business hours of the establishment at which the records are located when calculating the deadline.
Therefore, you would have until 1:00pm west coast time or 4:00 pm your time to produce these records and still be in compliance.
10 Common mistakes to avoid when completing your OSHA Form 300A. Click here to read more.