How do I count the days if an intermittent worker was previously
scheduled for days off during a period he or she is assigned limited
duty or days away from work for an Injury or illness?
You must count the number of calendar days the employee was unable
to work as a result of the injury or illness, regardless of whether
or not the employee was scheduled to work on those day(s). 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.
If an employee is exposed to chlorine or some other substance at work and
oxygen is administered as a precautionary measure, is the case recordable?
If oxygen is administered as a purely precautionary measure to an employee
who does not exhibit any symptoms of an injury or illness, the case is not
recordable. If the employee exposed to a substance exhibits symptoms of an
injury or illness, and is given oxygen as treatment then the case is recordable.
(Reference: Federal CPL 2-0.131 - Recordkeeping Policies and Procedures
Manual, question 7-15)
An employee sustains a lost time injury while operating a company vehicle on personal
business and on his own time, is the case recordable?
Employee use of the vehicle on personal business falls under the following exception
to recording found in Section 14300.5: “The injury or illness is solely the result
of an employee doing personal tasks (unrelated to their employment) at the establishment
outside of the employee's assigned working hours”.
Are prophylactic treatments recordable if they involve medications given for the
prevention of complications i.e. antibiotics for the prevention of infection or
injection of vaccines?
Section 14300.7 provides a complete list of all treatments considered “first aid” for
purposes of Article 2 and states (in part) that first aid includes “administering tetanus
immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are
considered medical treatment)”. All other vaccines given for the purpose of treatment
would fall under medical treatment and are recordable.
Do I have to provide copies of all Form 300 and 301s if an employee (as opposed to a union
representative) requests copies of all the records for the entire company.
When an employee, former employee, personal representative, or authorized employee
representative asks for copies of your current or stored Cal/OSHA 300 forms or a
current or stored annual summary for an establishment the employee or former employee
has worked in, you must give the requester a copy of the relevant Cal/OSHA 300 forms
and annual summaries by the end of the next business day (Reference: 14300.35(b)(2)(C)).
When an employee, former employee, or personal representative asks for a copy of the Cal/OSHA
Form 301 Incident Report describing an injury or illness to that employee or former employee,
you must give the requester a copy of the Cal/OSHA 301 Incident Report containing that
information by the end of the next business day.
On the Form 300, above columns G, H, J, and I, it states...“check ONLY the most serious result.”
If an employee is injured and has both lost workdays and restrictions, are the lost workdays
always considered the most serious? What if the number of restricted workdays far exceeds the days lost.
Employers must classify each case on the 300 Log in accordance with the most serious outcome associated
with the case. The outcomes listed on the form are: death, days away, restricted work/transfer, and
“other recordable.” (Reference: Federal CPL 2-0.131 - Recordkeeping Policies and Procedures Manual,
Chapter 2, Para 1.E.) Lost workdays are more serious than restricted workdays.
The counting cap of 180 calendar days...can that be a combined total of lost workdays and restricted days?
The employer may stop counting when the total number of days away, restricted or transferred reaches 180.
(Reference: Federal CPL 2-0.131 - Recordkeeping Policies and Procedures Manual, Chapter 2, Para 1.E.)
When a company has multiple establishments, a Form 300 is maintained for each establishment. Is the
Form 300A also for each establishment or for the total company?
As indicated, the standard requires a separate Form 300 for each establishment. Section 14300.32
states “Create an annual summary of the injuries and illnesses recorded on the Cal/OSHA Form 300
using the Cal/OSHA Form 300A Annual Summary of work-related Injuries and Illnesses” (Reference:
14300.32(a)(2)). The instructions printed on the Cal/OSHA Form 300A, states “All establishments
covered by CCR Title 8 Section 14300 must complete this Annual Summary, even if no work- related
injuries or illnesses occurred during the year.”
Form 300A asks for the "annual average number of employees" and "total hours worked by all
employees last year.” Is that the average and the total for the entire company or for each
The 300A is a compilation of the information for an establishment and therefore the number
of work hours must also equate to the establishment.
With reference to the Cal/OSHA Form 300A, when the company has multiple establishments, does
the highest-ranking person at each establishment sign, or the highest-ranking person in the company,
regardless of location?
For the purpose of certification, Section 14300.32
states “The company executive who certifies the log must be one of
the following persons: (A) An owner of the company (this is required only if
the company is a sole proprietorship or partnership); (B) An officer of the corporation; (C) The
highest ranking company official working at the establishment; or (D) the immediate supervisor of
the highest ranking company official working at the establishment.”