black friday shopping is done, the stockings are hung ... time for osha logs!

The holidays are in full gear and children everywhere are getting excited for Santa’s annual visit.  For those of you in certain industries with more than 10 employees, this time of year also holds something a little more special for you: it is about time to prepare your OSHA logs!  To help spread a little more holiday cheer, I thought I would pass along a little early present for you in the form of a recently published OSHA guidance letter!

Back in August, an employer sent OSHA an inquiry into OSHA’s record keeping requirement after an employee cut his index finger while working.  This sort of incident happens all the time, even in very safe workplaces, and so I am sure the OSHA-savvy among you are mentally doing the Non-Recordable Injury Dance, since you know that employers are not required to report injuries that don't require treatment beyond first-aid.  Right? Not so fast

As it turns out, while walking to the employer’s first-aid kit to retrieve a Band-Aid, the employee crossed paths with a co-worker, who happened to have a Band-Aid in his pocket.  The co-worker offered to help the employee by applying the Band-Aid to the employee’s finger.  As the co-worker applied the Band-Aid, the employee caught sight of a small amount of blood on his finger, became light-headed from the sight of it, and fainted.  As you may recall, while first-aid injuries do not need to be recorded, the loss of employee consciousness does.  So while the original finger-cut didn’t require inclusion on the OSHA logs, the fainting after seeing the blood from the cut must be properly recorded.

Employers have until February 1 to post their OSHA 300A summary forms.  So while I don’t mean to ruin your holiday spirit, taking the time now to complete your 300 and 301 forms will make completing the 300A form a breeze, and will give you more time in January for focusing on more pressing new-year tasks.