OSHA 300A forms must post by February 1, plus changes for 2015
OSHA takes recordkeeping requirements very seriously and employers should be aware of a major posting deadline that is fast approaching. All employers required to keep Form 300, the Injury and Illness Log, must post Form 300A, the Annual Summary of Job-Related Injuries and Illnesses, in a workplace common area by February 1, 2015. Even if there were no recordable incidents in 2014, companies required to maintain records still must post the summary with zeros on the total lines.
- Which employers must maintain records?
While employers with fewer than 11 employees in the entire company at all times during 2014 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 Log(s) of Work-Related Injuries & Illnesses for accuracy.
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.
Forms can be downloaded here.
- Executive certification
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
- An officer of the corporation
- The highest-ranking company official working at the site
- The immediate supervisor of the highest-ranking company official working at the site
- Posting period
The summary must be posted for three months in a common area of the workplace, from February 1 to April 30. It should be in a conspicuous area where notices to employees are customarily placed and where it can't be altered, defaced or covered by other posted material. Copies should be made available to any employee who might not see the summary (such as a remote employee who works from home). 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.
- Reportable injuries
Deciphering OSHA's recordkeeping rules to determine if an employee's injury or illness is recordable is challenging. Recordable injuries are work-related and serious. OSHA defines a serious injury as one that results in a fatality, loss of consciousness, days away from work, a restricted work schedule or job transfer, a significant injury or illness diagnosis by a health care provider, or that requires medical treatment beyond basic first aid. Employers should not report incidents that require only basic first aid. 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.
- Changes in 2015
It is important to note that beginning January 1, 2015 there was a change in the recordkeeping requirements. Employers are now required to report all work-related fatalities within 8 hours and all in-patient hospitalizations, amputations, and losses of an eye within 24 hours of finding out about the incident. In addition, more companies are required to keep records as the list of exempt industries has changed.