Occupational (OSHA) and Environmental Hazards/Recording days with 2 years involved

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Question
I have an employee who was injured on 10/15/12.  He had 77 restricted days in 2012, which does not meet the 180 days cap.  He also had a period in 2013, where he was completely off, and then restricted again for a few months.  Do I log the 2013 lost & restricted days on the new 2013 log, or put them back on the 2012 log?

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Subject: Recording days with 2 years involved

Question: I have an employee who was injured on 10/15/12.  He had 77 restricted days in 2012, which does not meet the 180 days cap.  He also had a period in 2013, where he was completely off, and then restricted again for a few months.  Do I log the 2013 lost & restricted days on the new 2013 log, or put them back on the 2012 log?

Answer: Lynne, No - you do not list the employee on the 2013 log. You estimate (based on the best information available at the time - the end of the year) the lost and/or restricted work days at the end of 2012 up to the cap of 180 days and then enter that number(s) on the 2012 log so it can be closed. Does this result in truly accurate accident/injury numbers - in my opinion, NO. However it makes OSHA happy because you will have complied with their rules and regulations. For their instructions see: the OSHA Recordkeeping Handbook at:

https://www.osha.gov/recordkeeping/handbook/index.html#1904.4

"Section 1904.7 General Recording Criteria  (b) Implementation (3)(ix) If a case occurs in one year but results in days away during the next calendar year, do I record the case in both years?
No, you only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap."

I would also suggest you check this set of rules occasionally as they are subject to change. (And are!) I hope this answers your question and if I can be of further assistance, please feel free to ask.

Michael Brown, CSP Retired

Occupational (OSHA) and Environmental Hazards

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Mike Brown CSP Retired

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I specialize in the professional management of occupational safety and health as well as workers` compensation to reduce losses and improve production and address related issues through a comprehensive approach by senior management using proven principals.I worked for over twenty (20) years in the management of occupational safety, health and workers` compensation and safety training (Retired from employment in 1996 due to a stroke, which prevented the extensive travel required).

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