POST YOUR INJURY LOG (300A) ON EMPLOYEE NOTICE BOARD 2-1-26 TO 4-30-26

TO:                  Clients

FROM:            Sam Celly, BChE MChE JD CSP

DATE:             January 2, 2026

SUBJECT:       POST YOUR INJURY LOG (300A) ON EMPLOYEE NOTICE BOARD 2-1-26 TO 4-30-26

LOG 300, 300A & 301 REQUIRED FOR AUTO DEALERS

IN THIS NEWSLETTER WE COVER
Record of all work-related illnesses and injuries (Log 300)

Posting requirements (Log 300A)

First-aid not recordable on Log 300

Serious injury reporting guidelines (Cal/OSHA & Fed-OSHA)

Electronic recordkeeping submission

Background:  Cal/OSHA and Fed-OSHA require employers to keep a record of occupational injuries and illnesses using OSHA Log 300 and to post a summary on the employee notice board from February 1 to April 30, 2026.  Keep annual injury log in files for 5 years beyond the current year. 

Forms & Guidance to Fill:  Fed-OSHA and Cal/OSHA forms are identical in nature.

California Forms:

Cal/OSHA exempts certain industries: https://www.dir.ca.gov/t8/14300_2.html

Federal-OSHA Forms:  https://www.osha.gov/recordkeeping/RKforms.html (Form 300, 300A, and 301)

Fed-OSHA exempts certain industries: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html

Posting Requirements: Form 300A (Summary of Work-Related Injuries & Illnesses) for 2025 must be posted on the employee notice board from February 1, 2026 to April 30, 2026.  ONLY Form 300A needs to be posted.  Disclosing injured employee name on the notice board is a big no-no.

Cal/OSHA Guide on Completing Forms: http://www.dir.ca.gov/dosh/dosh_publications/reckeepoverview.pdf

Fed-OSHA Guide on Completing Forms https://www.osha.gov/recordkeeping/tutorial.html

Recordkeeping Questions & Answers: See https://www.osha.gov/recordkeeping

Serious Injury:  Call your local OSHA office to report serious injury.  Cal/OSHA’s phone number is on the employee labor law poster.  California and Federal definitions of serious injury differ.  California Code on reporting serious injury is https://www.dir.ca.gov/title8/342.html

Commentary:  The forms are provided as a tool for the employer to document injuries, inform employees of accidents at the facility and allow OSHA inspectors to obtain a quick summary of accidents in the workplace. 

Employers must use this log as a management tool to gauge the nature and frequency of injuries in order to determine corrective measures for accident elimination and counsel employees who show up on the accident log on a repeated basis.  Certain highlights of the forms are as follows:

  • Requires records to include any work-related injury or illness resulting in one of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first-aid, loss of consciousness, or diagnosis of a significant injury or illness by a physician or other licensed health care professional. 
  • Requires a significant degree of aggravation before a preexisting injury or illness becomes recordable.
  • Requires employers to record cases when injured or ill employees are restricted from their “normal duties,” which are defined as work activities employees regularly perform at least once per week.
  • You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days.
  • Focus on days away or days restricted or transferred.  Rules rely on calendar days instead of workdays!
  • Requires employers to establish a procedure for employees to report injuries and illnesses and to tell their employees how to report.  Employers are prohibited from discriminating against employees who report.  Employee representatives will have access to those parts of OSHA Form 301 relevant to the employees they represent.
CAL/OSHA REPORTING GUIDELINESEmployers are required to report incidents within 8 hours to Cal/OSHA as follows:Any fatality.Any inpatient hospitalization for work related injury or illness, for anything other than medical observation or diagnostic testing must be reported.An amputation, the loss of an eye, or any serious degree of permanent disfigurement, but does not include any injury or illness or death caused by an accident on a public street or highway, unless the accident occurred in a construction zone.Call the local Cal/OSHA office as listed on your labor law poster. You may search the closest office or report the serious injury/fatality via email: https://www.dir.ca.gov/dosh/report-accident-or-injury.htmlAn employee trips in the service driveway of your dealership during normal course of business and seeks medical treatment.  Employee comes back to work the next day but continues treatment of physiotherapy and medication.  After 6 months, the MD states that only surgery can cure the knee problem and the employee proceeds with knee replacement surgery.  The issue is whether this knee accident is now Cal/OSHA reportable as a serious injury accident.  Yes, the accident must be reported to Cal/OSHA under the serious injury reporting statutes (Section 342). Simply stated, Cal/OSHA has no sunset clause such as the one found in Federal regulations.
 
FED-OSHA REPORTING GUIDELINES (i.e. AZ, CO, HI, ID, NV, TX)Employers have to report the following events to Fed-OSHA:All work-related fatalitiesAll work-related in-patient hospitalizations of one or more employeesAll work-related amputationsAll work-related losses of an eyeEmployers must report work-related fatalities within 8 hours of finding out about it.For any in-patient hospitalization, amputation, or eye loss employers must report the incident within 24 hours of learning about it.Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Furthermore, for an inpatient hospitalization, amputation or loss of an eye, then incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.Call the OSHA 24-hour hotline at 1-800-321-6742 (OSHA) or Report online.

Questions Asked During Reporting:

  1. Time and date of accident/event
  2. Employer’s name, address and telephone number
  3. Name and job title of the person reporting the accident
  4. Address of accident/event site
  5. Name of person to contact at accident/event site
  6. Name and address of injured employee(s)
  7. Nature of injuries
  8. Location where injured employee(s) was/were taken for medical treatment
  9. List and identity of other law enforcement agencies present at the accident/event site
  10. Description of accident/event and whether the accident scene or instrumentality has been altered.

Electronic Recordkeeping Submission: Businesses such as auto dealers with 250 or more employees at any time during the previous calendar year, and the regulations require your establishment to keep records, then you must electronically submit information from Form 300A Summary of Work-Related Injuries and Illnesses to OSHA. See California regulations and Federal regulations.

DISCLAIMER: The contents of this newsletter are for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 35 years. Sam is a Certified Safety Professional (No. 16515) certified by the National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Sam is a member of the American Chemical Society (No. 31176063), American Industrial Hygiene Association (No. 124715), and National Association of Dealer Counsel (NADC). Sam also serves on the Board of Orange County American Industrial Hygiene Association and on CA Industrial Hygiene Council (CIHC). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.

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