Should you post your OSHA 300 log?
Scenario: You are the Safety Manager for your company and are responsible for completing the OSHA 300 Log. It is time for you to have your new Plant Manager sign the “Summary of Work-Related Injuries and Illnesses” Form 300-A so you can post it as required by the standard. You spent quite a bit of time explaining to him how the whole OSHA recordkeeping process works, and he demonstrated quite an interest in what you were doing and the types of injuries your plant was experiencing.
As you are leaving his office, he makes the following statement to you: “When it comes to safety, we have no secrets around here. I think it would be a great idea if you post the entire 300 Log along with the Summary so people see just exactly what type of injuries we are having.”
Question: How should you respond to his statement?
Answer: The instructions that accompany the OSHA recordkeeping forms do include the following Question and Answer: “When must you post the Summary? You must post the Summary only–not the Log–by February 1 of the year following the year covered by the form and keep it posted until April 30 of that year.”
The following was taken from a letter of interpretation:
“12/18/2003 – Posting requirements for the OSHA 300 Log and OSHA 300-A Summary Form“.
“While our rules do not require the Form 300 to be posted, the regulation also does not prohibit an employer from posting the Form 300 along with the Form 300-A. However, if the employer does choose to post the full Form 300 Log, they should post the Log in an area only accessible by those granted access under the rule (i.e., employees, former employees, employee representatives, and an authorized employee representative). If the posting area is accessible by others (e.g., members of the public) the employer must remove or hide all names of the injured or ill employees as set out in Section 1904.29(b)(10). In addition, 1910.29 prohibits the employer from including the employee’s name for “privacy concern” cases whenever the Form 300 Log is made available to coworkers, former employees, or employee representatives.”