Volume 2, Issue 2 - January 31, 2014

February 1 is the annual OSHA Injury and Illness Recordkeeping deadline for employers, unless they have only 10 or fewer employees or are in low-hazard industries such as retail, service, finance, insurance or real estate.

On that date employers are required to review their OSHA 300 Log; verify entries are complete and accurate; correct any deficiencies; use the injury data to develop a 300A Annual Summary Form; and certify the accuracy of the 300 Log and the 300A Summary Form.

The Form 300A is a summation of the workplace injuries and illnesses recorded on the OSHA 300 Log during the previous calendar year, as well as the total hours worked by all employees covered by the OSHA 300 Log that year.

The 300 Log and the 300A Annual Summary Form must be signed by a “company executive,” defined as an owner of the company; a corporate officer; highest ranking company official working at the establishment; or immediate supervisor of the highest ranking company official working there.

After certifying the recordkeeping documents, OSHA requires employers to post the signed copy of the 300A Summary Form in the workplace, where it must remain until April 30.

Even if your facility had no recordable injuries or illnesses during the year, OSHA requires you to prepare and post a 300A Form.

After April 30, employers can remove the 300A Form, but must keep copies of the OSHA 300 Log, the 300A Annual Summary Form, and 301 Incident Report forms for five years.

A common mistake is to file and forget the old 300 Logs. OSHA rules also require you to update logs with newly-discovered injuries or illnesses for the recording year, along with any changes that are found during the five-year retention period.