OSHA recordkeeping requirements mandate that all employers who are required to maintain an OSHA 300 Log of Work-Related Injuries and Illnesses prepare, certify and post a summary of the previous year’s log between Feb. 1st and Apr. 30th each year, even if no incidents occurred in the preceding calendar year.
Employers with ten or fewer employees and employers in certain industries are normally exempt from federal OSHA injury and illness recordkeeping requirements, including the annual OSHA 300A Summary posting. A list of exempt industries can be found on our website. Remember that the Bureau of Labor Statistics may still select exempted employers to participate in an annual statistical survey.
The OSHA 300A form summarizes the workplace injuries and illnesses recorded on the OSHA 300 Log during the previous calendar year, as well as the total hours worked that year by all employees covered by the OSHA 300 Log.
By Feb. 1st employers must:
- Review their OSHA 300 Logs
- Verify the entries on the OSHA 300 Log are complete and accurate
- Correct any deficiencies discovered
- Use the OSHA 300 Log data to calculate an annual summary of injuries and illnesses and complete the OSHA 300A Summary Form
- Certify the accuracy of the OSHA 300 Log and the OSHA 300A Summary (certification must be done by a “company executive”)
- Post the OSHA 300A Summary in a common area where notices to employees usually are posted through 30th; Note: The 300 Log contains confidential information which should not be posted
Employers must maintain a copy of the OSHA 300 Log and the signed and “certified” OSHA 300A Summary for five years. In addition, OSHA 300 Logs must be updated with newly discovered recordable injuries or illnesses, or to correct previously recorded injuries and illnesses to reflect changes that have occurred in the classification or other details.
OSHA’s E-Recordkeeping Rule
This Feb. 1st requirement to prepare, certify and post OSHA 300A summary should not be confused with the electronic data submission requirement of OSHA’s E-Recordkeeping Rule. The Feb. 1st deadline is only for the internal hard copy posting of 300A Summary for your employees to see. The E-Recordkeeping Rule, on the other hand, requires only certain employers to electronically submit data from their OSHA 300A Annual Summary to OSHA via their ITA (Injury Tracking Application) online portal. The deadline for those submissions is Mar. 2nd.
If you haven’t started to prepare the summary yet and need assistance, please contact us today.