Employers are required to maintain an OSHA 300 log recording all workplace injuries and illnesses. OSHA zealously enforces this requirement, because it believes accurate OSHA 300 logs help identify the causes and potential preventative measures for on-the-job injuries. A company that packs Hershey’s chocolates located in Palmyra, Pennsylvania, recently felt the effect of OSHA’s zeal.
Student workers complained to the Labor Department about working conditions in Exel’s facility. The complaints triggered a multi-month investigation and audit of the plant and its operations. During the investigation, OSHA discovered at least 42 cases where the employer had failed to report injuries during a four year period. This meant 43% of all injuries at the facility had gone unreported.
But it gets worse. OSHA found the employer had acted willfully, when it failed to report injuries. This upped the ante. OSHA cited Exel for penalties totaling $283,000 and went out of its way to publicize the investigation. We should learn from Exel’s experience and view the publicized investigation and penalties as OSHA’s way of communicating its intention to scrutinize employers’ injury logs.