5.4 Running the system through the year
Everything in this course is a task with a rhythm: something that happens within seven days, or every week, or in February, or once a year. Written out as a calendar it fits on one page, and the point of writing it out is that nothing in Part 1904 reminds you — the deadlines are real and the prompts are yours to build.
1 The year on one page
| When | What | Source |
|---|---|---|
| 8 hours | Report a work-related fatality to OSHA | 1904.39(a)(1) |
| 24 hours | Report an in-patient hospitalization, an amputation or a loss of an eye | 1904.39(a)(2) |
| Next business day | Provide a copy of the 300 Log to an employee or their representative who asks | 1904.35(b)(2)(iii) |
| 7 calendar days | Enter a recordable case on the 300 Log and complete the 301; provide 301s to an authorized employee representative who asks | 1904.29(b)(3); 1904.35(b)(2)(v)(B) |
| Weekly or per the state rule | Jobsite walk-around inspection; crew safety meeting reviewing it | 1926.20(b)(2); WAC 296-155-110(5), (9) |
| December | Review the log line by line; close out day counts; hunt the cases that never arrived | 1904.32(a)(1), (b)(1) |
| By February 1 | Total, certify by a company executive and post the 300A | 1904.32(b)(2)-(4), (b)(6) |
| By March 2 | Electronic submission for covered establishments | 1904.41(a), (c) |
| Until April 30 | Keep the summary posted, unaltered and uncovered | 1904.32(b)(5)-(6) |
| Annually | Review the written programs that name an interval; review the incident investigation program; re-evaluate hazard controls | 1926.1153(g)(2); OSHA investigation guide; OSHA 3885 |
| 5 years | Retain the log, the summary, the privacy case list and the 301s — and keep updating the stored logs | 1904.33(a), (b)(1) |
2 The December review, done properly
1904.32(b)(1) asks you to review the entries “as extensively as necessary to make sure that they are complete and correct”. That is an instruction to go looking, not to proofread. Five passes cover it.
- 1Re-read every case against the classification rules. Cases that were open in June often got their column from an early guess.
- 2Close out every day count, or enter an estimate and note that it is one.
- 3Reconcile against the clinic bills, the workers compensation claim list and the first aid log. Cases that never reached you live in those three places.
- 4Reconcile the hours against payroll, and confirm the population matches the cases.
- 5Check that every privacy concern case is on the confidential list and nowhere else.
3 Who does what
Most failures in this system are handoff failures rather than knowledge failures: the clinic note that reached payroll, the restriction agreed verbally on site, the investigation that finished without anyone telling the recordkeeper the classification had changed. Naming the handoffs fixes most of it.
| From | To | What has to move, and when |
|---|---|---|
| Supervisor | Recordkeeper | Every injury or illness reported, same day — recordable or not, that is not the supervisor's call |
| Clinic or occupational health | Recordkeeper | The treatment given and any work restriction, in writing, on the day it is issued |
| Investigation team | Recordkeeper | Any change in the facts that affects classification, whenever it emerges |
| Recordkeeper | Crews | What the log is showing, at the crew meeting and when the summary goes up |
Two written questions to the treating professional on every case remove most of the second row's ambiguity: can this employee perform all the routine functions of their job, and can they work a full shift? Those are the exact tests of 1904.7(b)(4)(vii).
4 A management review worth the hour
Once a year, look at the system rather than at the cases. OSHA's investigation guide lists an annual program review among the marks of an effective incident investigation program — to identify and correct program deficiencies and to identify incident trends — and the same logic applies to the whole apparatus.
- Lagging: the four rates, three years side by side, with case counts and hours shown.
- Leading: near misses reported, inspection findings raised, the share of corrective actions closed by their due date, and the share verified rather than marked done.
- Quality: the proportion of corrective actions that were engineering or higher rather than administrative or PPE; investigation time from incident to closed action.
- Pattern: where the root causes cluster — the same procedure, the same area, the same shift, the same machine family.
- Gaps: training that fell due and was not given; written programs with no review date; competent persons named for work nobody does any more.
5 What to keep, and where
Only some of this has a federal retention period. The rest is decided by your program, your contracts and your state — which means it is decided by you, and the worst answer is not deciding.
| Record | Period | Set by |
|---|---|---|
| 300 Log, 300A, privacy case list, 301s | 5 years after the end of the calendar year covered | 1904.33(a) |
| Bloodborne pathogens training records | 3 years | 1910.1030(h)(2)(ii) |
| Fall protection training record | The latest record is maintained | 1926.503(b)(2) |
| Crew safety meeting minutes | 1 year (Washington), 3 years (Oregon, construction and manufacturing) | WAC 296-155-110(8); OAR 437-001-0765(13) |
| Walk-around inspection records | Until the job is complete (Washington); 1 year (California) | WAC 296-155-110(9); 8 CCR 3203(b)(1) |
| Training documentation generally | At least 1 year (California) | 8 CCR 3203(b)(2) |
| Incident investigation reports | No federal period | Your program — most keep them as long as the log |
6 What the system is for
It is worth ending where the rules do not. Part 1904 produces a count. The count feeds rates, the rates feed comparisons, and the comparisons feed decisions about where to spend attention. None of that is the point on its own.
The point is the loop: something goes wrong or nearly goes wrong, somebody says so without fear, somebody looks at why it was possible rather than who did it, something about the work changes, somebody checks that the change held, and the people who reported it hear what happened. The paperwork in this course is what makes each of those steps visible to the next person — including to whoever inherits your job.
If you take one habit from all five parts, take this one: write down the reasoning, not just the answer. The classification you can justify, the rate whose inputs you can show, the root cause you can trace to a decision, the action someone verified. None of it costs more than a few extra minutes, and all of it is what separates a system from a filing cabinet.
- The deadlines are 8 hours, 24 hours, next business day, 7 days, February 1, March 2, April 30 and 5 years
- The December review is a search, not a proofread — reconcile against clinic bills and claims
- Most failures are handoffs: supervisor to recordkeeper, clinic to recordkeeper, investigation to recordkeeper
- Review the system annually with leading indicators beside the rates, not the rates alone
- Only some records have a federal retention period; decide the rest and write the rule down
- Write down the reasoning, not just the answer — it is what makes the system survive you
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.