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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 case occurs in one year but results in days away during the next calendar year, employers should record the injury or illness only once using the date the injury occurred, and log 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 it is time to prepare the annual summary, employers should estimate the total number of calendar days that the employee is expected 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.

For example, it may happen that any employee gets injured in December and is still away from work (or on restrictions) in January of the following year. All days away or days of restriction must still be entered under the December entry. The purpose of counting days is to compare the severity of injuries (more days means more severe). Since only the total number of days is relevant for that purpose, it does not matter if those days continue into a new calendar year.

Employers must continue to update the OSHA 300 Log during the five-year retention period. However, they need not update the 301 Incident Report or 300A Summary. For example, if an employee injured in December finally returns to work in March (after the 300A is already posted), the employer should update the 300 Log with the day count. However, the employer does not need to update or re-post the 300A.