End of year injury recordkeeping: Top three challenges

The start of a new calendar year creates some unique challenges for injury recordkeeping. These include recording cases that carry over to the new year, addressing a reported incident that happened last year, and preparing the 300A Annual Summary.

If an employee is still on restrictions next year, how do I enter days on the 300A?

If an employee is away from work or on restrictions when the calendar year ends, OSHA says to estimate the day count on the 300 Log and use the estimate to complete the 300A. Later, go back and update the 300 Log when the exact day count is known. You do not have to update the 300A after it was posted. Also, if you submitted data through OSHA’s Injury Tracking Application, you do not have to resubmit after revising the actual day count.

For example, suppose an injury on December 28 requires an estimated 35 days restriction. The employer would use that estimate on the 300A. Later, the employer learns that the actual count was 37 days, so the employer updates the 300 Log. The employer need not update the 300A after posting, however.

All days get recorded under the original entry. The purpose of counting days is to indicate relative severity (a case with 22 days away is more severe than a case with 9 days away). For that purpose, it does not matter if the days occurred in a different calendar year.

In January, an employee reported an injury from last year. How do I record that?

If an employee reports an injury that happened last year, you record the case using the date of the incident, if known. Some conditions develop over time (like carpel tunnel) without a specific date of onset. If that happens, OSHA says to record the incident using either:

• The date the employee first reported symptoms, or
• The date that the case became recordable (e.g., medical treatment or restrictions were given).

For example, in January 2024, an employee reports a minor cut from December 16, 2023. The cut got infected and now needs medical treatment. You would record the case on the 2023 Log using the December 16 date.

If you already certified the 300A, you do not need to update it with this new case. Similarly, if you already submitted data through the Injury Tracking Application, you do not have to resubmit with the new case.

To prepare the 300A, OSHA says to review the 300 Log for accuracy. What does that mean?

Reviewing the 300 Log for accuracy doesn’t require examining every entry. However, you should spot check a number of cases to make sure they were entered correctly. Potential errors include:

• Column (E) requires a location. Writing “warehouse” or “office” does not provide a good description. OSHA gives examples such as “loading dock north end” or “second floor storeroom.”
• Column (F) requires a description of the injury, the body part, and the cause of the injury. A common error is listing the injured body part (like “fractured forearm”) but failing to list the cause. OSHA gives the example, “Second degree burns on right forearm from acetylene torch.” Also, body parts like arms, legs, or eyes should specify left or right.

If the establishment did not have any recordable incidents, employers must still prepare and post a 300A with zeros in the columns and (if required) electronically submit the 300A.