OSHA Forms 300A must post by February 1

At the end of each calendar year, all employers required to keep Form 300 must create, certify, and post an annual summary of injuries and illnesses recorded on the OSHA 300 Log of Work Related Injuries and Illnesses. The summary is OSHA Form 300A, The Summary of Work-Related Injuries and Illnesses. While employers must fill out the Form 300 Log when a recordable, work-related injury or illness has occurred, the Summary must be filled out and posted annually even if no recordable, work-related injuries or illnesses occurred during the year.

Form 300A summarizes a business’s total number of fatalities, missed workdays, job transfers or restrictions, and injuries and illnesses as recorded on Form 300. It also includes the number of employees and the hours they worked for the year. Companies with multiple job sites should keep a separate log and summary for each location that’s expected to be operational for at least a year.

Which employers must maintain records?

While employers with fewer than 11 employees in the entire company at all times during 2015 and certain low-hazard industries are exempt, in general, employers with 11 or more employees are required to maintain records of occupational injuries and illnesses as they occur on Form 300.

Employers should begin by reviewing these logs for accuracy. Under OSHA’s injury and illness recordkeeping requirements, employers must record a work-related injury or illness if it results in one or more of the following:

  • Death
  • Days away from work
  • Restricted work
  • Transfer to another job
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Diagnosis by a physician or healthcare professional of a significant injury or illness

 

OSHA’s recordkeeping page provides more detail. If the injury is of a sensitive nature, such as sexual assault, then the employer should write “privacy case” in the box for the worker’s name.

Who is responsible for the summary?

A company executive must certify the summary. In so doing, the executive is certifying he/she has reviewed the related records and that the posted summary is accurate, true and complete. OSHA describes this requirement as imposing “senior management accountability” for the integrity and accuracy of the data.

Company executives are defined as:

  • An owner of the company (only if the company is a sole proprietorship or partnership);
  • An officer of the corporation;
  • The highest-ranking company official working at the establishment; or
  • The immediate supervisor of the highest-ranking company official working at the establishment.

When must the OSHA 300A form be posted?

The summary for 2015 must be posted no later than February 1, 2016 and kept in place until April 30, 2016. Employers must keep the records for five years following the calendar year covered by them, and if the employer sells the business, he or she must transfer the records to the new owner.

Where must the OSHA 300A form be posted?

A copy of the annual summary must be posted in a conspicuous place or places where notices to employees are customarily posted. Employers must ensure that the posted annual summary is not altered, defaced, or covered by other material. Copies should be made available to any employee who might not see the summary (such as a remote employee who works from home). Download forms here.

New letters of interpretation

Deciphering OSHA’s recordkeeping rules to determine if an employee’s injury or illness is recordable is challenging. Throughout the year, OSHA issues letters of interpretations. Below is a list of interpretations issued in 2015.

  • 11/12/2015 – Clarification on the recording of injuries involving broken or chipped teeth
  • 11/06/2015 – Clarification on the work-related exemption involving personal tasks outside the assigned working hours
  • 10/19/2015 – Determining who is the responsible party to record an injury or illness
  • 10/19/2015 – Determining whether an injury or illness is work-related and recordable
  • 07/06/2015 – Use of kinesiology tape is not considered medical treatment beyond first aid
  • 06/25/2015 – How to maintain logs for employees across multiple locations.
  • 04/13/2015 – Clarification regarding the applicability of the recording criteria for an injury occurring while commuting to/from work.
  • 04/07/2015 – Clarification of the reporting requirements contained in 1904.39, regarding specific types of eye and tooth injuries
  • 02/12/2015 – Clarification of the applicability of the recording criteria for cases occurring while traveling to/from an airport for work-related travel
  • 02/12/2015 – Clarification regarding the applicability of the recording criteria involving restricted work
  • 02/10/2015 – Clarification regarding the jurisdiction of the applicability of the recording requirements in state territorial water

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