When to enter estimated day counts on the OSHA 300 Log
If an injured employee will miss work or be on restrictions for an unknown number of days, OSHA requires entering an estimated day count on the 300 Log. When the final day count is known, employers must update the entry with that number. OSHA addresses that in 29 CFR 1904.7(b)(3).
Note that an incident could involve both days away and days of restriction. If that happens, the 300 Log would include day counts in both the days away column and the restriction/transfer column, but would be classified by the most serious outcome (days away).
Estimate for the Annual Summary
If the day count continues into the next calendar year, employers can use the estimate to prepare the 300A Annual Summary. OSHA addresses this at 1904.7(b)(3)(ix). Again, the employer must later update the 300 Log when the actual number of days becomes known. However, the employer does not need to update the 300A after it was certified and posted, even if the estimated day count was later corrected.
When a case carries over to another calendar year, do not re-enter the case in the next year’s 300 Log. The purpose of counting days is to compare the severity of an injury or illness (more days means more severe). For that purpose, it doesn’t matter if the day count crossed a calendar year.
For example, if an injury that occurred in December involved 97 days of restriction, the fact that those days continued into the next calendar year does not matter since the number simply indicates the severity of the condition.
Count all calendar days
Employers must count all calendar days that the employee would have been unable to work, or should have performed only restricted work, regardless of scheduled working days. That includes weekends, holidays, vacation days, and other non-working time. Employees work different schedules and some businesses remain open on weekends and holidays, so OSHA requires counting calendar days for consistency. The reason, as noted, is to accurately compare the severity of conditions.
Sometimes an employee gets injured on a Friday, or just before a holiday or planned vacation, but returns the next scheduled working day. Does the employer need to count days away or restriction? OSHA clarified that employers only need to count those days if they receive information that the employee should not have worked, or should have performed only restricted work, during those non-working days.
If a doctor tells an employee to “take it easy” until the next scheduled working day, the employer should request clarification. For example, if the employee would have been restricted from performing one or more routine job functions or from working a full shift, that would count as restricted work (even if the employee wasn’t scheduled to work). For related information, see our article, Restrictions must affect routine functions to count as restricted work.
OSHA’s regulation at 1904.7(b)(4)(vii) also states, “If you are unable to obtain this additional information from the physician or other licensed health care professional who recommended the restriction, record the injury or illness as a case involving restricted work.” Note that an incident can involve days away or restrictions even if the employee did not get medical treatment beyond first aid.
Key to remember: When an employee needs restrictions or time off, employers might not know how long the condition will last, but they must enter an estimated day count on the 300 Log until the exact day count is known.
