How OSHA Inspectors Think: 300A Annual Summary

How OSHA Inspectors Think: 300A Annual Summary

Jill James

Jill James

Chief Safety Officer

Jill James brings an unrivaled perspective on risk, regulation and liability. With 14 years of experience as a Senior OSHA Safety Investigator with the State of Minnesota, and nearly a decade in the private sector as a safety program manager, Jill is a passionate advocate for training ROI.

OSHA 300 Logs

February 1st will be here sooner than you know, which means now is the time to start gathering data you need for your 2019 OSHA 300A form (annual summary). Specifically, I’m talking about the annual average number of employees AND the total hours worked by all employees last year. This can be particularly tricky if you have multiple locations requiring a separate 300 log and 300A form for each site. How many separate 300 logs do you keep? 

Pro Tip: Reach out to your payroll people or other number-crunchers for these numbers now, so none of you are panicking later! 

The annual summary (300A) regulation is: 1904.32(a)-(b)(6)

Permit-Required Confined Spaces

Are your permit confined spaces labeled, ensuring employees are aware of danger? The regulation requiring labeling also contains the words which must appear on the label: 1910.146(c)(2)

Pro Tip: Have you identified all of your permit spaces? Identifying spaces could be an activity for your safety committee members--having them work alongside departments to ensure all spaces get identified. Remember to define the elements of a permit required confined space before starting such an activity.

Tongue Guards & Tool Rests

Sounds funny doesn’t it? Ask any inspector, this is likely the lowest of the low-hanging citation fruit, yet a solid hazard to avert. I’m talking bench grinders here. Basically, every medium-risk work environment has at least one.

What I saw most commonly, was that both machine guards were missing or were out of alignment. Now that you’ve pictured a bench grinder with abrasive wheels, picture the ‘tool rest’. The tool rest needs to be adjusted to within 1/8” of the wheel, and the ‘tongue guard’—also called the ‘peripheral protecting member’—on the other end of the exposed wheel, needs to be adjusted to within ¼” of the wheel.

There are many more requirements regarding abrasive wheel machinery, however, these I cited most often: 1910.215(a)(4) & 1910.215(b)(9)