The End-of-Year OSHA 300 Sweep: Cleaning Up Your Logs Before February

It is a December ritual. You are trying to close out the year, finish projects, and manage holiday schedules. But if you handle safety compliance, there is one task you cannot push to January: the OSHA 300 log review. By February 1st, you must post the OSHA 300A summary. If your data is messy, your summary will be wrong, your electronic submission to the ITA will be wrong, and your DART rate will be artificially high.

The difference between a "recordable" injury and "first aid" is often a matter of millimeters or milligrams. Now is the time to audit every entry while the details are still fresh.

The "Medical Treatment" Trap

The most common error in OSHA logs is over-recording. A well-meaning supervisor writes down an incident where an employee got a cut, went to urgent care, got it cleaned, and returned to work. Is that recordable?

It depends entirely on what happened at urgent care.

• Cleaning and Bandaging: First aid (Not recordable).
• Steri-Strips or Butterfly Bandages: First aid (Not recordable).
• Sutures, Staples, or Glue: Medical treatment (Recordable).
• Tetanus Shot: First aid (Not recordable).
• Prescription Antibiotics: Medical treatment (Recordable).

If you don't chase down the medical records now, you might leave a "First Aid" case on your log as a "Medical Treatment" case simply because they went to a doctor. That inflates your injury rate. Review the doctor's notes. Did they prescribe 800mg Ibuprofen (prescription strength)? Recordable. Did they tell the worker to take two 200mg Ibuprofen (OTC strength)? First aid.

Restricted Duty Calculation

Another area that gets sloppy in December is the day count. If a worker was on restricted duty for three weeks in November, did anyone verify when they actually returned to full duty?

Remember OSHA's counting rules: 1. Do not count the day of the injury. 2. Count calendar days, not scheduled work days. If the doctor writes "no use of left hand for 7 days," that includes Saturday and Sunday even if you are closed. 3. Cap the count at 180 days.

Go back and check the "Date Returned" column. If it's blank, you have an open case that needs closure before you run your summary.

The "Pain Only" Cases

Musculoskeletal disorders (MSDs) are tricky. An employee reports a sore back. You send them to the clinic. The doctor finds no objective trauma but prescribes rest and physical therapy. This is recordable.

However, if the employee reports a sore back, goes to the doctor, and the doctor says "take it easy and use ice," and the employee performs their full normal job duties, it is likely not recordable. The key is whether the condition was work-related (OSHA presumes it is if it happened at work) and whether it met the general recording criteria (medical treatment, days away, restriction).

Privacy Concern Cases

Did anyone suffer an injury to a reproductive organ? A needle stick with contaminated blood? A mental illness? These are "Privacy Concern Cases." You must record them, but you must not enter the employee's name on the 300 log. Instead, write "Privacy Case."

If you leave names on these entries and then hand the log to an employee who asks to see it (which is their right), you have committed a violation. Check your log for sensitive injuries now.

Prepare for the 300A Posting

On February 1st, the OSHA 300A Annual Summary must go up in a conspicuous place. It must be signed by a company executive—not the safety manager, but the owner, CEO, or highest-ranking site official. Their signature certifies that they have "examined" the log.

If you hand them a messy log in February, they are certifying bad data. Do the sweep now. Verify every entry against the 1904.7 standard. Reclassify the first aid cases. Update the day counts. When January arrives, you’ll be ready to sign, post, and submit to the ITA without the panic.

Next step: Use the Worksafely SMB Recordkeeping Wizard to audit your entries against the "First Aid" exception list.