Covered employers must post injury and illness summaries from February 1 through April 30.
Don’t get caught by OSHA for not posting the OSHA 300A Form. This is a reminder that employers have an obligation to post a copy of OSHA’s Form 300A. The 300A reports an employer’s total number of deaths, missed workdays, job transfers or restrictions, and injuries and illnesses as recorded on Form 300 during 2015. It also includes the number of workers and the hours they worked for the year. Only the summary must be posted. The OSHA 300 Log itself does not need to be displayed but must be available for inspection by employees, their representatives or OSHA investigators. Employers with multiple job sites should keep a separate log and summary for each location that is expected to be operational for at least a year.
The 300A Summary must be signed by the highest-ranking person at the site, not the person filling out the form or the Human Resources Director. The company executive signing the Form 300A is 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: owner of the company (but only if the company is a sole proprietorship or partnership); officer of the corporation; highest-ranking company official working at the establishment; or immediate supervisor of the highest-ranking company official working at the establishment.
Businesses with 10 or fewer employees and those in certain low-hazard industries are exempt from OSHA recordkeeping and posting requirements. As of January 1, 2015, certain previously exempt industries are now covered. Lists of both exempt and newly covered industries are available on OSHA’s website, www.osha.gov. Visit OSHA’s Recordkeeping Rule webpage for more information on recordkeeping requirements – https://www.osha.gov/recordkeeping/index.html.
Stephen A. Burt, MFA, BS
Chair, AOHP Government Affairs Committee
April 2016