Just a few days remain before the February 1 deadline to post your company’s annual OSHA Form 300A. OSHA Form 300A is the form on which covered employers must summarize the work-related injuries and illnesses that occurred at their company in the previous year. Here are some tips to help you comply:
Who must complete an OSHA Form 300A?
All U.S. employers with more than 10 employees who are not in a partially exempt industry. Partially exempt industries include certain low hazard retail, service, finance, insurance and retail industries. A list of these industries can be found here. You must complete the Form 300A even if no work-related injuries or illnesses occurred during the previous year.
What information do I need to complete the OSHA Form 300A?
You will need to review the injury and illness data that your company recorded on your OSHA Form 300 Log for all of 2013. To fill in the summary information on Form 300A, verify that the information on the log is accurate for the past year and count up the total number of work-related injuries and illnesses from the log to complete certain category totals, such as the number of deaths, total number of injuries, total number of cases resulting in days away from work, etc. OSHA provides fillable forms and instructions for both the Form 300 Log and Form 300A Summary here. If your company did not experience any work-related injuries or illnesses in 2013, you still need to complete the summary form by entering zeros in the summary categories. Employers with more than one physical location should complete separate Forms 300 and 300A for each location.
Does the Form 300A need to be signed?
Yes, in fact, a company executive must sign the Form 300A certifying that he or she has reviewed both the OSHA Form 300 Log and Form 300A Summary and he or she reasonably believes that the Summary Form is correct and complete. Be certain that the executive signing the form is one of the following: (a) owner of the company (but only if the company is a sole proprietorship or partnership); (b) officer of the corporation; (c) highest ranking company official working at the establishment; or (d) immediate supervisor of the highest ranking company official working at the establishment.
What do I have to post in the workplace? Where must it be posted? For how long?
Your Form 300A must be posted in your workplace for the three month period from February 1 to April 30. You do not post the Form 300 Log. You should post the Form 300A in a conspicuous place where other employee notices are posted. Make sure that the form does not get covered by other documents on a bulletin board or does not get defaced, altered or marked up during the three month posting period.
Do I have to keep the forms after the posting period is done?
Yes. OSHA requires employers to retain their Form 300 Logs and Form 300A Summaries for five (5) years following the year on which they report.
Do I have to send the forms to OSHA?
No. OSHA does not require employers to send either the Form 300 Logs or Form 300A Summaries to the agency, unless specifically asked to do so. (OSHA has proposed an online reporting procedure that would require employers to provide data on work-related injuries and illness to the agency each year but that proposal is not yet in effect. Stay tuned!)
What are the consequences of failing to complete and/or post an OSHA Form 300A?
Employers are subject to inspection for required OSHA recordkeeping of work-related injuries and illnesses, including the completion and posting of OSHA Form 300A. Employers found to have failed in their recordkeeping obligations may be issued administrative citations and fines, ranging from a de minimus violation to a serious/willful violation.
So, if you haven’t completed your company’s Form 300A yet, follow these tips and get busy – the February deadline is just around the corner.