Each year, you must post your OSHA Form 300A Summary report from February 1 through April 30, even if your employees have not experienced any workplace injuries or illnesses. As of April 30th, you should take the report down and file it in your records. Note too that both federal and state OSHA offices require some evidence that the form was actually posted for the proper period. You can make a signed, written note on the back of the form to that effect.
All employers required to keep Form 300, the Injury and Illness Log, must utilize the annual summary Form 300A to comply with posting requirements even if there have been no recordable injuries or illnesses, as the Occupational Safety and Health Administration (OSHA) will continue to focus on record-keeping violations during the year.
The summary must include the total number of job-related injuries and illnesses that occurred in the covered year. The summary Form 300A reports a business’s 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 Form 300. It also includes the number of employees and the hours they worked for the year.
The 300A summary must be posted at each location from Feb. 1 to April 30, in a conspicuous area where notices to employees are customarily placed. Copies of the form should be provided to any employees who may not see the posted summary because they do not regularly work onsite. Employers have a duty to update and maintain records for five years plus the current year and provide them upon request for inspection by OSHA investigators. Employers must also ensure that the annual summary is not altered, defaced or obscured during the posting period.
Those employers who maintain these records in electronic form should still retain the signed posted summary after the Feb. 1 to April 30 posting period, to prove that it was properly signed.
Before the annual summary is prepared, the [OSHA] record-keeping rule imposes an express duty to review the log to verify that entries are complete and accurate. Employers must review the records as extensively as necessary to ensure accuracy.
OSHA requires companies to enter the average number of employees and the total hours they worked on the summary form. An employer can plug those figures into a formula to calculate injury and illness incidence rates and compare them with the data of other establishments in similar industries.
OSHA scrutinizes the injury and illness record-keeping forms for even minor errors in descriptions and boxes checked. Take time to review the forms for technical errors as well as to review accident reports, first aid logs and other related materials to ensure that all recordable incidents have been included and that records are consistent.
If you have any further questions about OSHA logs, how to complete them, or if an injury would be considered recordable, don’t hesitate to reach out to our dedicated risk management team!
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