THE COHEN GROUP
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The Cohen Group Newsletter - Volume 5  Issue 1, Article 1.  January 2003

The NEW! Cal/OSHA Recordkeeping - Forms 300 and 300A
Tim Bormann, CIH

We have come to the end of the first year under the revised Cal/OSHA recordkeeping requirements for recording injuries and illnesses.  As of January 1, 2002, the OSHA Log 200 (Log and Summary of Occupational Injuries and Illnesses) that we had been using for many years is no longer used.  We now have three forms to use; Form 300, 300A and the 301????.  The Form 300 (Log of Work-Related Injuries and Illnesses) is quite similar in appearance and function to the log 200.  Information from the Form 300 is to be summarized and transferred to a Summary of Work Related Injuries and Illnesses (Form 300A).  The new summary (Form 300A) must be posted from February 1 to April 30 and signed by a company executive, certifying its accuracy.  In previous years, the log 200 was posted for the month of February.  The Form 300 does not need to be posted.  Form 300A requires summarizing of the following: 

·         Total number of occupational injuries (non first-aid) and illnesses;

·         Total number of days of job restriction or transfer; and

·         Total number of days away from work

Cal/OSHA injury and illness records do not need to be kept if your company has 10 or fewer employees at all times during the last calendar year (2002) or for a number of specific industries in the retail, service, finance, insurance and real estate sectors (classified as low hazard).  To maintain consistency with the federal standard, some industries in California, which have been exempt in the past from recordkeeping requirements may no longer be exempt, and some which were not exempt are now exempt.  Exempt industries can be found in 8CCR§14300.2. 

Failure to post a copy of the Form 300A can result in a Cal/OSHA citation.  Every establishment (not exempt from recordkeeping requirements) must maintain the Form 300 and post the Form 300A in a conspicuous place (i.e, where notices are customarily posted for employees).  A separate Cal/OSHA Form 300 and 300A must be maintained for each location where business is conducted or where services and operations are performed for one year or longer.  You do not have to keep a separate Form 300 or 300A for short-term establishments (less than one year).  Therefore, some construction sites will need to keep their own log of injuries and illnesses.

Form 301 is the Injury and Illness Incident report which replaced the former OSHA Form 101, Supplementary Record of Occupational Injuries and Illnesses.  The Form 301 contains specific information on the injury.  An equivalent form, such as the report of Occupational Injury may replace this form or Illness provided by your insurance carrier.  The Form 301 is not posted.

Records may be kept at central location if the business:

·         Transmit information about the injury or illness from the establishment to the central location with 7 days;

·         Produce and send the records from the central location when you are required to provide records to a government representative, employee, former employee or employee representative;

·         Have the address and telephone number of the central location where records are kept at the each worksite;

·         Have personnel available at the central location where records are kept during normal business hours to transmit information from the records

Regulations regarding recordkeeping of work-related injuries or illnesses can be found in 8CCR§ 14300 through 14400. The regulations and forms can be accessed through the Department of Industrial Relations website at www.dir.ca.gov under Cal/OSHA regulations.  If you have any questions regarding how and what to record, exempt industries, posting requirements, etc. you can also call The Cohen Group.