The deadline for posting the OSHA 300A, is due February 1. The form must be “certified” by a company executive and posted in an area where employee notices are normally posted, i.e. lunch room, stock room, etc. The posting should remain thru April 30 each year. The OSHA 300A Summary must be posted even if no recordable cases occurred during the year.
The basis for the Form 300A is the OSHA Form 300, or the “log”. It is to be updated throughout the year and must be current to within 7 days. All work-related injuries and illnesses to your employees resulting in death, loss of consciousness, days away from work or restricted duty, or medical treatment beyond first aid must be recorded. Recording injuries on the OSHA 300 is independent of the decision to file a worker’s compensation claim and does not imply any “fault” by the employer.
If you are unsure about the recordkeeping requirements for your business, there are two classes of employers that are partially exempt from routinely keeping injury and illness records. First, employers with ten or fewer employees at all times during the previous calendar year are exempt. Second, establishments in certain low-hazard industries are also partially exempt from routinely keeping records. OSHA provides a list of these exempt industries on its website at http://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html.
Some key points to know when completing your OSHA Form 300:
- Columns G, H, I, J – Check only ONE of the boxes per case. Choose the one that describes the most serious consequence of the incident. For example, if a worker was temporarily disabled and then returned to modified duty, the box in Column H would be check for “days away from work”. Incorrectly marking these boxes will cause inaccuracy in your incident rate calculations.
- Columns K & L – These columns represent calendar days and not business days. Once the total days entered in both columns reaches 180, you may stop counting. The total of the two columns for any given case should not exceed 180 days. There are a number of conditions that can impact these numbers and OSHA has guidance and interpretations available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9638
A separate OSHA Form 300 must be kept for each location or jobsite (respects construction) expected to be in operation for one year or longer. A single OSHA Form 300 may be kept to cover multiple short-term worksites. The logs may be kept electronically as long as they can be retrieved within 4 hours of request by an OSHA representative.
You do not have to submit the completed Form 300 or 300A to OSHA unless specifically requested to do so. Select businesses may be requested to complete and submit an Annual OSHA Injury and Illness Survey. This survey would be received via mail and have Department of Labor markings.
For more information, interpretations, and the forms needed to meet the recordkeeping requirements, visit http://www.osha.gov/recordkeeping/index.html.
As always, If you have any questions or need guidance for this or other OSHA compliance concerns, please feel free to call our VP of Risk Control and Claims, Jeff Hixon. His phone number is (240-864-9169). He can also be reached via email, firstname.lastname@example.org.