Employers can delete cases from the OSHA 300 Log if they later determine the incident was not work-related and should not have been recorded. However, employers cannot delete entries based on information that treatment already provided was not necessary.
If an employee receives medical treatment, days away, or restrictions, a work-related case remains recordable even if the employer later learns that treatment or restrictions were not necessary.
Suppose an employee passes out at work and the employer records the incident. Later, the employer learns that the loss of consciousness was solely caused by a personal medical condition such as diabetes or narcolepsy. The employer may delete the 300 Log entry because OSHA provides an exemption for incidents involving non-work-related symptoms that happen to occur at work.
Employers must use caution, however, because any contribution from the work environment makes the case work-related. For example, suppose an employee reports a shoulder strain from performing job duties and gets restrictions. The employee later admits that the condition started while doing chores at home. If the job duties likely contributed to the condition, OSHA considers the incident to be work-related. The employer cannot delete this case from the 300 Log.
According to OSHA, a recommendation for medical treatment from a licensed health care professional makes a case recordable, even if the employee did not need the treatment. For example:
Now, one caveat is whether an injury or illness actually occurred. If the employee did not experience an injury or show any signs or symptoms of an illness, there is nothing to record. Still, some of OSHA’s guidance seems conflicting. For example:
Why the difference? The employee given oxygen did not experience an injury or illness, so there’s nothing to record. The other employee, however, got an injury (a tick bite). No matter how minor the injury, the recommended antibiotic made the case recordable. The employer cannot delete the tick bite case from the 300 Log upon learning that the antibiotic was not necessary.
Employers may remove an entry from the 300 Log upon learning that the case was not work-related, even if the employee received medical treatment or missed days of work. However, employers cannot remove work-related incidents based on information (even from a medical professional) that medical treatment, restrictions, or days away were not necessary.
Since OSHA created the recordkeeping rule to presume that any event a work is work-related, even an employer with a strong safety record could have to record cases on the OSHA 300 Log. Those entries might need updating, and in rare cases they can be deleted. The Incident Center in the J. J. Keller® SAFETY MANAGEMENT SUITE helps you track recordable cases, count days away or restriction, and create the annual summary.