Union Approach to Health and Safety: - United Steelworkers

USES AND LIMITATIONS OF OSHA 300 LOGS
OSHA 300 Logs are valuable tools for workers and unions to use in evaluating the types,
frequency and severity of workplace injuries and illnesses. This information, in turn, is
invaluable in identifying the location and nature of workplace hazards that should be
eliminated or controlled.
However, OSHA 300 Logs do not provide a complete and accurate accounting of all the
injuries and illnesses experienced in a workplace. Not all injuries and illnesses are
required to be recorded. In addition, injuries and illnesses that may be required to be
recorded under the recordkeeping rule are, in fact, not recorded by some employers. The
following are examples of injuries and illnesses that may not be recorded on an OSHA
300 Log:
an assault on a worker by a patient or client that does not result in treatment of
more than first aid,
musculoskeletal disorders that an employer does not accept as work-related,
early signs and symptoms of some musculoskeletal disorders,
many occupational illnesses (cancer and other illnesses) that an employer does not
accept as work-related,
work-related stress,
needlestick injuries occurring to workers employed in doctor’s offices (an exempt
industry), and
injuries which result in lost time or restricted activity only for the day of the
incident.
In addition, employer policies, programs and practices may discourage workers from
reporting injuries and illnesses. Safety incentive programs that offer prizes to workers
who do not report injuries, and injury discipline policies that threaten discipline to
workers who do report, have both been shown to decrease the reporting of workplace
injuries and illnesses.
Unions should use additional methods to identify symptoms, injuries and illnesses that
are occurring in the workplace. These methods include (but are not limited to) worker
surveys, body mapping, and requesting additional information (such as workers
compensation data, data from medical clinic visits, and results of hearing tests). Workers
and unions can use their rights to information under the OSH Act and unions can use
their rights to health and safety information under Section 8(d) of the National Labor
Relations Act (or other applicable collective bargaining law) to obtain some of this
information and data. Worker surveys and body mapping in particular are effective
methods for identifying workers’ symptoms before full-blown injuries or illnesses
develop. Hazards can then be identified and targeted for correction, and more serious
injuries and illnesses prevented.