Mid-Year OSHA Recordkeeping Check: Why August Is the Right Time to Audit Your 300 Log
August 28, 2017 · 5 min read
By Jeff Schroeder, Foster Special Instruments
Why audit the OSHA 300 Log in August instead of waiting for February?
Every employer required to keep OSHA injury and illness records has to post the Form 300A annual summary where employees can see it, every year, from February 1 through April 30, covering the prior calendar year's cases. Under 29 CFR 1904.29, cases have to reach the log within 7 calendar days of the employer learning about them, which means by August the current year's log already holds seven or eight months of entries. That's enough data to catch a pattern, a missed hearing loss case, or a mislabeled first-aid incident while the people involved still remember what happened and the paper trail is still easy to pull. Waiting until January to reconcile the whole year at once turns a quick cross-check into a scramble against the February 1 posting date.
What does a mid-year 300 Log audit actually check?
A useful mid-year review walks the log against three sources instead of trusting the log alone: the first-aid and medical-treatment records from the clinic or safety office, any days-away or restricted-duty paperwork from HR, and the results from any required medical surveillance testing, including audiometric testing under 1910.95 and the standard threshold shift calculation in 1904.10. Each recordable case should trace back to a dated source document, and each STS or significant diagnosis flagged during the year should have a corresponding 300 Log entry, not just a results letter sitting in a personnel file. The audit also checks that the clock on 1904.39's four reportable outcomes, fatality, in-patient hospitalization, amputation, or loss of an eye, was actually met when those cases occurred, since a late report doesn't get fixed by catching it months later.
Mid-year OSHA recordkeeping audit checklist
| Check | Source document | What it catches |
|---|---|---|
| Log entries vs. clinic/first-aid records | Safety office or on-site clinic log | Medical treatment miscoded as first aid |
| Days-away/restricted cases | HR leave and modified-duty records | Missing or incomplete restricted-work entries |
| Audiometric STS flags | Annual hearing test results | Recordable hearing loss cases never logged |
| Reportable outcomes | Incident reports, hospital records | Late or missed 8-hour / 24-hour reports under 1904.39 |
| Case closure status | Return-to-work documentation | Open cases that should be updated before 300A totals are pulled |
What happens if the February posting deadline catches a gap?
If a missing or miscoded case surfaces for the first time while preparing the 300A summary in January, the employer still has to correct the log, which is allowed, but a late-discovered case that should have been reported to OSHA under 1904.39 cannot be made timely after the fact. A mid-year check doesn't change the reporting clock for a case that already happened, but it keeps new gaps from compounding for another five months, and it gives a safety manager time to retrain whoever is making the first-aid-versus-medical-treatment call before the next incident instead of after the annual summary already has an error in it.
Who has to certify the 300A summary before it's posted?
29 CFR 1904.32(b)(4) requires a company executive, defined as the owner, an officer of the corporation, the highest-ranking official working at the establishment, or that official's immediate supervisor, to certify the summary by signature. That certification states the executive reviewed the records and believes the annual summary is correct and complete. A mid-year audit gives that executive something real to sign off on in January: a log that's already been reconciled against clinic records, HR leave data, and medical surveillance results, rather than a 300A total the executive is certifying on faith because nobody checked it since the previous February.
How Foster handles this
Foster's hearing conservation work is one of the recordkeeping sources an audit like this has to check, since a confirmed standard threshold shift under 1904.10 is recordable whether or not anyone remembers to log it. Our hearing testing service flags a confirmed STS the day results come back, and our calibration records give the employer a dated, defensible source document if an auditor or inspector asks where a hearing-related entry came from. For employers managing recordability decisions and 300A posting dates across more than one testing requirement, Foster's Compliance Workspace product ties each flagged case to its CFR citation so it doesn't sit unlogged until the next January scramble. See our OSHA recordable vs. reportable post for the specific tests that decide whether a case belongs on the log at all. Request a quote for a hearing conservation program review.
Frequently asked questions
When does the OSHA 300A summary have to be posted?
The Form 300A annual summary must be posted from February 1 through April 30 each year, covering the prior calendar year, in a conspicuous location where notices are normally posted for employees.
Is a mid-year audit required by OSHA?
No. OSHA requires the 300 Log to be kept current throughout the year under 1904.29 and the 300A posted on schedule, but it doesn't mandate a specific interim review. A mid-year check is a practice, not a regulatory requirement, aimed at catching errors before the posting deadline forces a rush.
Can a company fix a 300 Log entry it finds was wrong months later?
Yes. The log can be corrected when new information comes to light, and OSHA expects it to be accurate at the time it's posted. The complication is reporting, not recording: a case that should have been reported to OSHA within 8 or 24 hours under 1904.39 can't retroactively meet that clock once the window has passed.
Does audiometric testing ever show up as an OSHA recordable case?
Yes. A confirmed standard threshold shift that also crosses the 25 dB hearing level threshold under 1904.10 is a recordable hearing loss case, separate from the general medical-treatment and days-away criteria that cover most other injuries.
Sources
Foster runs occupational health compliance programs end to end — testing, calibration, training, and records.
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