NU-SAF-122 — OSHA RECORDKEEPING (300 / 300A / 301)

Tier 2/3/4 — Procedure + Field Card + Form · Rev DRAFT · Drafted August 2, 2026 · Owner: Office (Adam today) Parent: NU-SAF-100 §5, element 18. Feeds from: NU-SAF-121 (every incident record starts there). Regulation: 29 CFR Part 1904.

THE GATE

Any injury that gets more than first aid goes on the OSHA 300 log within 7 calendar days — record NU-SAF-122-F. A fatality gets OSHA on the phone within 8 hours. A hospitalization, an amputation, or a lost eye gets OSHA on the phone within 24 hours. And every February 1 the signed 300A goes on the wall and stays up through April 30.

None of this waits for the workers' comp claim, the insurance adjuster, or the lawyer. The clock starts when the injury happens, not when the paperwork feels ready.

1. IS NOVA EXEMPT? (probably not — keep the log)

OSHA lets two kinds of employers skip the routine logs:

1. Small employers: companies that had 10 or fewer employees at every point during the entire last calendar year (1904.1). That is peak headcount, company-wide, counting every employee — field, office, part-time, and temps Nova supervises day to day. One day at 11 and the exemption is gone for the following year.
2. Low-hazard industries on OSHA's NAICS exemption list (1904.2, Appendix A to Subpart B). Utility construction is not on that list. NAICS 237110 (water/sewer/utility line construction) and 238910 (site preparation) are recordkeeping-covered industries. Nova does not get out on industry.

So the only door is headcount, and Nova is at or past it. [Adam: confirm peak headcount for 2025 and for 2026 to date — count everyone, including the July hires. At or near 10, keep the log regardless: it costs one line per incident, the exemption can vanish mid-year, and every prequal asks for the 300A anyway.]

Two things are NEVER exempt, at any size: the severe-injury phone calls in §4, and OSHA's right to ask for records in an inspection. The size exemption only covers the routine 300/301/300A paperwork.

2. RECORDABLE vs FIRST AID (the actual 1904.7 test)

An injury or illness goes on the 300 log when all three are true:

1. It's work-related — it happened in the work environment or the work caused or contributed to it. The site, the yard, the truck on the way between jobs: all work environment. (Not work-related: the normal drive from home to the first site, doing a purely personal errand, or a cold/flu.)
2. It's a new case — not a flare-up of something already logged.
3. It meets at least one of these:

2.1 The first-aid line (this list is complete — if it isn't on it, it's medical treatment)

OSHA's first-aid list (1904.7(b)(5)(ii)) is exhaustive, which makes the call easy:

Nova translations: - Utility-knife cut, butterfly strip at the truck → not recordable. Same cut, urgent care puts in three stitches → recordable. - Doctor looks at a puncture, prescribes antibiotics "just in case" → recordable. The prescription is the trigger, not the wound. - Twisted ankle, he's on the truck handing tools for two days instead of in the pit → recordable (restricted work). - Mud splash to the eye, flushed clean at the truck, back to work → not recordable. Log it on the DFR anyway. - Heat cramps, water and shade per NU-SAF-112, finishes the day → not recordable. Ambulance runs IV fluids → recordable. - X-ray comes back clean, no treatment, no days → not recordable. Diagnostic-only visits don't count against Nova. Never talk a man out of getting checked to protect the log.

Special cases that are recordable by their own rule: needlestick or cut from a blood-contaminated sharp (1904.8), medical removal under an OSHA standard (1904.9), an OSHA-defined hearing-loss shift (1904.10).

When it's genuinely unclear, the Office makes the call within the 7 days, and writes one line on why. [Adam: name who makes the recordability call — recommend the Office/Billing Coordinator seat once filled (NU-GOV-005), you until then.]

3. THE THREE FORMS AND HOW THEY CHAIN

Nova does not build a new reporting pipeline for this. NU-SAF-121 is already the pipeline — injury happens, crew reports same day, Supervisor investigates, incident record gets written. This document adds the OSHA paper that hangs off that record:

Rules that matter:

• The 301 doesn't have to be OSHA's form. The workers' comp first-report or the NU-SAF-121 incident record satisfies it if it carries every 301 data field. [Adam: one-time check that the NU-SAF-121 form covers the 301 fields; add any missing ones there rather than running two forms.]
• The 300A gets certified by a company executive — for Nova that is Adam — who signs that he reviewed it and reasonably believes it's accurate. Not delegated to whoever typed it.
• Post the 300A even in a zero-injury year. A summary full of zeros still goes on the wall Feb 1 – Apr 30, where employees actually see it. [Adam: confirm the posting spot — recommend the yard board next to the OSHA poster.]
• Post the 300A, never the 300. The 300 has names on it.
• Days counting: calendar days, not workdays; don't count the day of injury; the days-away column and the days-restricted column each cap separately at 180 calendar days — a single case can carry up to 180 in each column.
• Electronic submission (1904.41): establishments in construction with 20–249 employees at peak must also submit the 300A to OSHA's Injury Tracking Application by March 2 each year. Nova is under 20 today, so this doesn't apply yet — but it triggers on headcount, not on choice. [Adam: revisit at every January headcount.] Separately, at 100+ employees in a designated high-hazard industry, full Form 300/301 data (not just 300A) must be submitted by March 2 (1904.41(a)(1), current Appendix B to Subpart E) — years away for Nova today, revisit alongside the 20-249 check.
• Privacy cases: injuries to intimate body parts, sexual assaults, mental illness, needlesticks, and similar get "privacy case" on the 300 instead of a name, with the name kept on a separate confidential list.
• Employee access: any employee, former employee, or their representative can see the 300 log; copies go out by the end of the next business day. That's the rule — don't make anyone ask twice.

4. THE PHONE CALLS (severe-injury reporting, 1904.39 — applies to every employer, no exemption)

How: call 1-800-321-6742 (1-800-321-OSHA), the nearest OSHA area office, or report online at osha.gov. Georgia private-sector work is federal OSHA. [Adam: confirm the nearest area office — Atlanta — and record its number in NU-SAF-121 (which owns the OSHA-call procedure) or a standalone office reference sheet — not NU-SAF-119's crew Emergency Block, which is a different, crew-facing set of fields.]

Who calls: the Supervisor or Adam — whoever NU-SAF-121 puts in charge of the aftermath. The call is Nova's, not the hospital's and not the insurance company's. Have ready: business name, location and time of the incident, what happened, who was hurt, and a contact number.

Order of operations is unchanged: 911 and the emergency plan (NU-SAF-119) first, family and NU-SAF-121 steps next, OSHA call within the window. An ER visit where he's treated and released is not reportable under this section — but it's very likely recordable under §2.

5. RETENTION — FIVE YEARS

Keep the 300, the 300A, and every 301 (or equivalent) for five years after the end of the calendar year they cover. During those five years, the 300 gets updated when a case changes — days away grow, a case reclassifies, a new case surfaces late. The 300A doesn't get re-certified after the year closes; the 300 stays live.

Where: the Safety Program folder today, the Softr record when the app lands — one place, not both. [Adam: confirm Softr is the system of record once live.]

6. NO POINTS FOR REPORTING — EVER

OSHA's anti-retaliation rule (1904.35–36) and Nova's own policy say the same thing, and NU-SAF-100 §1 and NU-PPL-403 already have the teeth:

• NEVER issue points, dock pay, or give anyone a hard time for reporting an injury — that direction is a federal violation and a fired-up OSHA complaint in one move.
• NEVER run an incentive that pays for "no recordables" — it pays for hiding, and hiding is the NU-PPL-403 zero-tolerance offense, not reporting.
• NEVER let the log wait on the comp claim, the adjuster, or a "let's see how it heals." Seven days.
• NEVER post or hand out the 300 with names where the 300A belongs.
• NEVER talk a man out of medical care to keep a case off the log.

7. DOT NOTE (adjacent record, not this one)

A crash on a public road while a crew is working or driving between sites goes on the OSHA 300 like any other work injury if it meets §2 — DOT status doesn't change that. Separately, motor carriers keep their own DOT accident register: Nova holds USDOT 4221697, currently inactive in SAFER (lapsed MCS-150; reactivation is an open office task). Draft position: Nova operates as if carrier rules apply. The DOT accident register and post-accident testing live in NU-FLT-315 §5 (testing decision) and §6 (accident register) — cross-reference on this document's issue, not a placeholder. [Adam: reactivation of the USDOT number is the gate for the whole NU-FLT-31x block — status?]

8. THE ANNUAL RHYTHM (what the Office does, and when)

Done when: a 300 log exists for the current year (even if empty), last year's certified 300A is posted every Feb 1 – Apr 30, every recordable hit the log within 7 days off the NU-SAF-121 chain, any §4 event was phoned in inside its window, and five years of records can be produced on request.

9. TIER-3 CARD — THE OSHA CLOCK (rides with the NU-SAF-121 card)

SOMEBODY GOT HURT BAD — THE CLOCK: 1. 911 first. NU-SAF-119. Nothing outranks the ambulance. 2. Supervisor + Adam on WhatsApp immediately (NU-GOV-004 escalation). 3. Killed → OSHA in 8 hours. Admitted to hospital, amputation, or lost eye → OSHA in 24 hours. 1-800-321-6742. Supervisor or Adam makes the call. 4. Everything else more than a band-aid → tell the Crew Lead today, NU-SAF-121 record starts, Office logs it inside 7 days. 5. Nobody gets points for reporting. Ever.

10. TIER-4 FORM — NU-SAF-122-F: OSHA 300 LOG (starter table)

NOVA UNDERGROUND — OSHA Form 300 equivalent · Year: 20___ · Establishment: Nova Underground [Adam: confirm establishment address for the header — the yard/office]

One line per recordable case. Check exactly one "case classification" box per line (the most serious outcome). Days = calendar days, not workdays; don't count the day of injury; the days-away column and the days-restricted column each cap separately at 180 calendar days — a single case can carry up to 180 in each column. Privacy case: write "privacy case" instead of the name.

Year-end totals (these feed the 300A): Deaths ___ · Cases w/ days away ___ · Cases w/ restriction/transfer ___ · Other recordables ___ · Total days away ___ · Total days restricted ___ · Injuries ___ · Illnesses by type ___ · Average employment ___ · Total hours worked ___

Example line is a sample, not a case — delete it before the log is used. This table becomes a Softr table under the training/records build; until then it lives as one sheet per year in the Safety Program folder.

11. WHAT THIS DOCUMENT NEEDS FROM ADAM

1. Confirm peak headcount for 2025 and 2026 to date (§1). This settles the exemption question on paper — but the draft position stands either way: keep the log.
2. Name who makes the recordability call (§2) — you today, the Office/Billing Coordinator seat when filled.
3. One-time field check of the NU-SAF-121 incident form against the 301 (§3) — so one form does both jobs.
4. Confirm the 300A posting spot (§3) and the nearest OSHA area office number for NU-SAF-119 (§4).
5. Open the 2026 log now. Anything recordable since January 1 goes on it retroactively — [Adam: any injuries beyond first aid in 2026 so far? The log starts with the true answer, not a clean sheet.]
6. USDOT reactivation status (§7) — office task, gates the NU-FLT-31x block.

NU-SAF-122 · Rev DRAFT · Nova Underground · Parent: NU-SAF-100 · Feeds from NU-SAF-121 · Record: NU-SAF-122-F · Update NU-GOV-000 register on issue · Uncontrolled when printed.