Injury & Illness Log Posting Period
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 Feb. 1, 2019. This year’s summary must include the total number of job-related injuries and illnesses that occurred in 2018.
Form 300A reports 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. If there were no recordable injuries or illnesses, a company must still post the form, with zeroes on the appropriate lines.
This February 1st requirement to prepare, certify and post 300A forms should not be confused with OSHA’s new Electronic Recordkeeping Rule. The February 1st deadline is only about the internal posting of 300A data for your employees’ eyes.
The E-Recordkeeping Rule, on the other hand, is a new requirement for certain employers to electronically submit data from their 300A Annual Summary forms to the Occupational Safety and Health Administration (OSHA) through a web portal. Depending on how OSHA resolves an internal policy debate and the outcome of legal challenges from labor groups, that data may also be shared publicly.
By February 1st every year, employers must:
- Review their OSHA 300 Log(s)
- Verify the entries on the 300 Log are complete and accurate
- Correct any deficiencies identified on the 300 Log
- Use the injury data from the 300 Log to calculate an annual summary of injuries and illnesses and complete the 300A Annual Summary Form
- 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 that year by all employees covered by the particular OSHA 300 Log.
4 Common 300A Mistakes
It is essential for employees to take occupational safety and health training to avoid workplace mishaps that result in injuries. But, we also see employers make the following four (4) common mistakes related to this annual Injury and Illness Recordkeeping duty:
- Not having a management representative with high enough status within the company “certify” the 300A
- Not posting a 300A for years in which there were no recordable injuries
- Not maintaining a copy of the certified version of the 300A form
- Not updating prior years’ 300 Logs based on newly discovered information about previously unrecorded injuries or changes to injuries that were previously recorded
Maintaining the 300A for Five Years
After the certified 300A Annual Summaries have been posted between February 1st and April 30th, employers may take down the 300A Form, but must maintain for five (5) years following the end of the prior calendar year at the facility covered by the form or at a central location, a copy of:
- Underlying OSHA 300 Log
- Certified 300A Annual Summary Form
- Any Corresponding 301 Incident Report Forms
In this technology era, many employers have transitioned to using electronic systems to prepare and store injury and illness recordkeeping forms. As a result, another common mistake employers make is to keep only the electronic version of the 300A, and not the version that was printed, “certified,” typically by a handwritten signature, and posted at the facility.
Accordingly, those employers have no effective way to demonstrate to the Occupational Safety and Health Administration (OSHA) during an inspection or enforcement action that the 300A had been certified. Learn more at no tuition-cost in our Introduction to OSHA online training.
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