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How should an employer record a case that results in days away from work?
  • The OSHA 300 Log provides space to record injury or illness that results in days away from work.

When an injury or illness involves one or more days away from work, employers must record the injury or illness on the Occupational Safety and Health Administration (OSHA) 300 Log with a check mark in the space for cases involving days away and an entry of the number of calendar days away from work in the number of days column. If the employee will be out for an extended period, employers must enter an estimate of the days the employee will be away, and update the day count when the actual number of days is known.

Employers should start counting days away on the day after the injury occurred or the illness began. The day that the injury occurred is not counted.

What if a doctor assigns days away but the employee reports to work anyway?

Employers must record these injuries and illnesses on the OSHA 300 Log using the check box for cases with days away from work and enter the number of calendar days away recommended by the physician or other licensed healthcare professional. If a physician or other licensed healthcare professional recommends days away, employers should encourage employees to follow that recommendation. However, the days away must be recorded whether or not the injured or ill employee follows the physician or licensed healthcare professional’s recommendation. If employers receive recommendations from two or more physicians or other licensed healthcare professionals, they may decide which recommendation is the most authoritative, and record the case based upon that recommendation.

Similarly, if the employee decides to stay home beyond what is recommended, employers may end the count of days away from work on the date the physician or other licensed healthcare professional recommends that the employee return to work.

How should an employer count weekends, vacation days, or holidays when the employee was not scheduled to work?

Employers must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether the employee was scheduled to work on those days. Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness.

May an employer stop counting days away if the employee leaves the company for a reason other than the injury?

If the employee leaves the company for some reason unrelated to the injury or illness, such as retirement, a plant closing, or to take another job, an employer may stop counting days away from work or days of restriction/job transfer. If the employee leaves the company because of the injury or illness, employers must estimate the total number of days away or days of restriction/job transfer and enter the day count on the OSHA 300 Log.

Is there a cap to the day count?

Employers are not required to continue to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180 in the total days away column will be considered adequate.

What if a case begins in one year and carries over into the next year?

If a work-related injury or illness occurs in one calendar year but results in days away from work or restricted duty in the following year, the employer must record the case only once, using the date of the original injury or illness on the OSHA 300 Log for that year. The employer must also record the total number of calendar days away from work or on restriction for that case on the same log entry.

If the employee is still away from work or on restricted duty when it is time to prepare the OSHA Form 300A annual summary, the employer must estimate the total number of days away or restricted and include that estimate in the summary. Once the actual day count becomes known, or when the case reaches the 180-day cap, the employer must update the OSHA 300 Log entry accordingly.

For example, if an employee is injured in December and continues to miss work or work under restrictions into January or later, all days away or restricted must still be recorded on the December case entry, even though some of those days occur in the next calendar year. The purpose of tracking days away or restricted is to measure the severity of the case, so the total number of days is recorded regardless of the year in which they occur.

Employers are required to update the OSHA 300 Log during the five-year retention period if the outcome or classification of the case changes (such as additional days away). However, employers are not required to update the OSHA 300A Annual Summary or the OSHA 301 Incident Report after they have been completed and posted.

If an employee reports an injury or illness and receives medical treatment this year, but states that the symptoms first arose at some unspecified date last year, on which year's log does the employer record the case?

In general, employers must record a case on the OSHA 300 Log for the calendar year in which the injury or illness occurred. This is based on the date of the work-related event or exposure that caused the condition, or when the case first meets OSHA’s recordability criteria (e.g., medical treatment, days away, restricted work).

If the employer cannot determine the exact date of injury or illness onset, OSHA allows the employer to use the best available information. In these situations, the employer should record the case based on the date the employee reported symptoms or received medical treatment, since that is the earliest identifiable date tied to the recordable condition.

Therefore, if an employee reports symptoms this year and cannot specify when they began in the prior year, the case should be recorded on this year’s OSHA 300 Log, using the date of reporting or treatment.

Employers should make a good-faith determination based on the information available. If additional, reliable information later establishes a more accurate onset date, the employer should update the OSHA 300 Log entry in accordance with the recordkeeping update requirements.