The start of a new calendar year creates some unique challenges for injury recordkeeping. These include recording cases that carry over to the new year, addressing a reported incident that happened last year, and preparing the 300A Annual Summary.
If an employee is away from work or on restrictions when the calendar year ends, OSHA says to estimate the day count on the 300 Log and use the estimate to complete the 300A. Later, go back and update the 300 Log when the exact day count is known. You do not have to update the 300A after it was posted. Also, if you submitted data through OSHA’s Injury Tracking Application, you do not have to resubmit after revising the actual day count.
For example, suppose an injury on December 28 requires an estimated 35 days restriction. The employer would use that estimate on the 300A. Later, the employer learns that the actual count was 37 days, so the employer updates the 300 Log. The employer need not update the 300A after posting, however.
All days get recorded under the original entry. The purpose of counting days is to indicate relative severity (a case with 22 days away is more severe than a case with 9 days away). For that purpose, it does not matter if the days occurred in a different calendar year.
If an employee reports an injury that happened last year, you record the case using the date of the incident, if known. Some conditions develop over time (like carpel tunnel) without a specific date of onset. If that happens, OSHA says to record the incident using either:
For example, in January 2024, an employee reports a minor cut from December 16, 2023. The cut got infected and now needs medical treatment. You would record the case on the 2023 Log using the December 16 date.
If you already certified the 300A, you do not need to update it with this new case. Similarly, if you already submitted data through the Injury Tracking Application, you do not have to resubmit with the new case.
Reviewing the 300 Log for accuracy doesn’t require examining every entry. However, you should spot check a number of cases to make sure they were entered correctly. Potential errors include:
If the establishment did not have any recordable incidents, employers must still prepare and post a 300A with zeros in the columns and (if required) electronically submit the 300A.
If a serious injury results in an unknown number of days away or restriction, employers must enter an estimated day count on the OSHA 300 Log. Tracking these incidents can be a challenge since employers may need to update entries from previous years. The Incident Center feature in the J. J. Keller® SAFETY MANAGEMENT SUITE helps you track recordable cases, count days away or restriction, and create the annual summary.