Feb. 1 is the deadline for employers to post 300-A Summary forms listing 2018 injuries and illnesses.
All employers who keep Part 1904 OSHA workplace injury and illness records need to review the 2018 OSHA 300 Log to ensure accuracy, correct any deficiencies and then create their 300-A Annual Summary.
The 300-A summary must be posted in an area where you normally place notices to employees by Feb. 1, 2019. It must remain visible in that location until at least April 30, 2019.
A company executive, such as the company owner or a corporation’s highest ranking official, must certify the summary is completely accurate.
Employers with ten or fewer employees or those whose NAICS code is for low-hazard industries exempted from OSHA injury and illness recordkeeping are exceptions to the posting requirement.
According to the law firm of Conn Maciel Carey LLP, there are four common mistakes employers make in preparing and posting the summary:
- Not having a management representative with high enough status within the company certify the 300-A
- Not posting a 300-A summary for years in which there were no recordable injuries
- Not maintaining a copy of the certified version of the 300-A form, or
- Not updating prior years’ 300 logs based on newly discovered information about previously unrecorded injuries or changes to injuries that were previously recorded.
Don’t confuse the 300-A with the Electronic Recordkeeping Rule
Another common mistake is confusing the 300-A summary with OSHA’s Electronic Recordkeeping Rule.
The Feb. 1 deadline is only for the internal hard copy posting of the 300-A summary for employees to see.
OSHA’s Electronic Recordkeeping Rule requires certain employers to electronically submit data from the 300-A summary form to the agency through its Injury Tracking Application.
The deadline to submit that data is March 2, 2019, although the state OSH programs in Maryland, Wyoming and Washington have not adopted the rule yet, and employers covered by the rule in those states are technically not required to submit data by the March 2 deadline.
For more information on OSHA recordkeeping requirements, visit www.osha.gov/recordkeeping.
