Are we required to fill-out the OSHA 300 Logs?

January 18th, 2013 by

Under the OSHA Injury and Illness Recordkeeping and Reporting Requirements, most employers are required to record work-related injuries and illnesses using the OSHA 300 Logs.  However, many businesses, including car dealerships, are currently exempt from most of the requirements, dependent on store’s primary Standard Industrial Classification (SIC) code.

All business activities that generate revenue have been assigned a SIC code.  The primary SIC code of a business is based on the activity that generates the most revenue.  As an example, several different business activities are conducted at an automobile dealership; however, most of the revenue typically comes from the selling of automobiles, therefore the SIC code for Automobile Sales, 5511, is used.

The Exemption for Automobile Dealerships
New and Used Car Dealers (SIC Code 5511), Used Car Dealers (5521), and Motorcycle Dealers (5571) are exempt from the requirements to maintain a log and post a summary of all work-related injuries and illnesses.  You must verify with your accounting department what SIC code they use to ensure you are actually exempt.  Be aware that OSHA inspectors are often unfamiliar with this exemption; so you may need to refer them to 29 CFR 1904.2.

Non-Exempt Facilities
There are several businesses that are associated with the car industry that are not exempt from the regulation.  For example, if offsite facilities are not clearly linked to the sales area of the dealership, the off-site locations may have a different SIC code.  Other examples of non-exempt businesses are:

  • Standalone Collision Centers
  • Standalone Auto Repair / Quick lube
  • Car Leasing Company
  • Truck Centers
  • Car Rental Company
  • RV Centers
  • Parts Warehouses
  • Boat and/or ATV Sales & Service

It is important to find out the SIC code being used for each location.  This is the only way to determine if you are exempt.

All Facilities Must Comply with OSHA’s Basic Reporting Requirements
All employers regardless of number of employees or the SIC code are required to report fatalities and multiple hospitalizations to OSHA.  Also, any facility that is asked by OSHA or the Bureau of Labor Statistics (BLS) to complete an Injury and Illness Survey (usually sent via mail) is required to do so.

Best Practices
Outside of exempt industries, OSHA 300 log usage is quite common.  It is widely considered a useful tool for tracking and identifying patterns with workplace illnesses and injuries.  Accordingly, some dealerships and dealer groups have elected to maintain OSHA 300 logs, regardless of the exemption, for the benefits provided as a management tool for loss control.

If you are not sure if your facility is exempt, or if you have other questions, please contact your KPA Engineer or ask your question at contact us. OSHA 300 log reporting forms can be found here: OSHA Reporting Forms.

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One Response to “Are we required to fill-out the OSHA 300 Logs?”

  1. Chelo Iniguez says:

    Tips on OSHA 300A:Do not forget to count employees not on your payroll (such as temporary workers) if they are under the direct supervision of your company.

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