OSHA Record-keeping Reminder
Employers should be reminded of their recurring obligation to post the OSHA Form 300A, Summary of Work-Related Injuries and Illnesses. 29 CFR 1904.32 requires employers at the end of each calendar year to complete the following:
- Review the OSHA 300 Log to verify that entries are complete and accurate, and correct any deficiencies identified.
- Create an annual summary of injuries and illnesses on the OSHA 300 Log.
- Certify the summary.
- Post the annual summary.
The summary must include the total number of work-related injuries and illnesses that occurred in the prior calendar year, the total year-end number of fatalities, missed workdays due to injury or illness on the job, job transfers or restrictions, and injuries and illnesses as recorded on the Form 300 Log. (If no recordable cases occurred, zeros should be entered for each column total.) The summary should also include the company’s name, establishment name and address, annual average number of employees covered by the OSHA 300 Log, and the total hours worked by all employees covered by the OSHA 300 Log.
The summary should be certified as complete and accurate by a company executive. The requirements of 1904.32 specify the following persons as qualified to certify the summary:
- Owner of the company (if the company is a sole proprietorship or partnership)
- Officer of the corporation
- Highest ranking company official working at the establishment
- Immediate supervisor of the highest ranking official working at the establishment
The company executive should examine the OSHA 300 Log and certify by signature that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and accurate.
Employers should post a copy of the summary for each work establishment in a conspicuous location or locations where notices to employees are customarily posted. The Form 300A summary for the prior calendar year should be displayed from February 1 through April 30 each year. Employers are responsible for ensuring that the posted annual summary is not altered, defaced, or covered by other material for the duration of the required posting period. An annual summary must be posted even if no recordable work-related injuries or illnesses occurred during the prior calendar year. Only the summary must be posted; the log does not have to be displayed but must be available to employees, their representatives, or OSHA inspectors. Companies with multiple jobsites/establishments should keep a separate log and summary for each location that is expected to be operational for at least a year.
The Bureau of Labor Statistics may still select employers to participate in an annual statistical survey.
Annual summary posting requirements are not replaced or superseded by OSHA’s electronic submission rules implemented during 2017. Establishments with 250 or more employees or establishments with 20 to 249 employees in certain high-risk industries were required to submit 2016 Form 300A summary data to OSHA electronically via OSHA, Injury Tracking Application (ITA). In addition to posting 2017 data according to 1904.32, these employers will be required to submit 2017 summary by July 1, 2018, via the ITA. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
Employers with establishments in OSHA-approved plan states that have not yet adopted the requirement to submit injury and illness reports are not currently required to submit data for establishments in the following states:
- South Carolina
Additionally, state and local government establishments in Illinois, Maine, New Jersey, and New York are not currently required to submit their data through the ITA.
Again, electronic submission of summary data does not supersede posting requirements, regardless of state or establishment size. OSHA is reported to be reviewing provisions of the Improve Tracking of Workplace Injuries and Illnesses rule and intends to publish a notice of proposed rulemaking to reconsider, revise, or remove portions of the rule in 2018.
For a list of industries (for establishments with 20 to 249 employees) required to submit Form 300A, see the following link: https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.html.
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