February Means it is OSHA Form 300A Season
Each year by February 1st, many employers with 10 or more employees must post the required OSHA Form 300A, which summarizes the employer’s recordable injuries and illnesses for the prior year. The Form 300A posting period is February 1 to April 30. An employer subject to this requirement must post the OSHA 300A even if the employer had no recordable injuries/illnesses in the prior year.
The data required for OSHA Form 300A is gleaned from Form 300, one not typically posted as it contains confidential medical information. Employees with no fixed work site or access to posted sites, such as field sales reps, must be provided with a copy of Form 300A.
Some industries are partially exempt from maintaining the OSHA Form 300A. Click here for a list of partially exempt industries.
Frequently Asked Question: I am new to filling out the OSHA Forms 300 & 300A. I have not had any training on how to fill out the forms. Where can I go for additional guidance?
Answer: Please visit the OSHA Recordkeeping Tutorial Page for additional guidance on how to complete the OSHA recordkeeping forms.
Compiling the OSHA Form 300 Log Data
The first step required by OSHA is for employers to review their OSHA Form 300 Log each year to verify that all entries are complete and accurate and to correct any identified deficiencies. Once that task is completed, it is then necessary to create an annual summary of those injuries and illnesses recorded on the OSHA 300 Log by utilizing the OSHA-provided Form 300A.
Completing the OSHA Form 300A Annual Summary
Simply total the columns on the OSHA 300 Log (if you had no recordable cases, enter zeros for each column total) and enter the calendar year covered, the company’s name, establishment name, establishment address, annual average number of employees covered by the OSHA 300 Log, and the total hours worked by all employees covered by the OSHA 300 Log. If you are using an equivalent form other than the OSHA 300-A summary form, as permitted under 1904.6(b)(4), the summary you use must also include the employee access and employer penalty statements found on the OSHA 300-A Summary form.
Frequently Asked Question: Is “Total hours worked by all employees” on the Form 300A actual work time after leave deductions?
Answer: Yes, this figure should reflect the actual number of hours worked by employees. Include hours worked by salaried, hourly, part-time and seasonal workers, as well as hours worked by other workers subject to day-to-day supervision by your establishment (e.g., temporary help services workers). Do not include vacation, sick leave, holidays, or any other non-work time, even if employees were paid for it. If your establishment keeps records of only the hours paid or if you have employees who are not paid by the hour, please estimate the hours that the employees actually worked.
Certification of the OSHA Form 300A Annual Summary
A company executive must certify that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete. OSHA defines a “company executive” as
• An owner of the company (only if the company is a sole proprietorship or partnership);
• An officer of the corporation;
• The highest ranking company official working at the establishment; or
• The immediate supervisor of the highest ranking company official working at the establishment.
The Safety, Health and Environment Manager or the Human Resources Manager generally would not meet this criterion.
Frequently Asked Question: Will OSHA accept an electronic signature on the 300A Summary?
Answer: An electronic signature is acceptable.
Posting the OSHA Form 300A Annual Summary
OSHA states that, in each establishment, you must post a copy of the annual summary in a conspicuous place or places where notices to employees are customarily posted. Typically, employers post this summary where other labor law posts exist to include areas where employees clock in for work or common break areas. You must protect the posting to ensure that the posted OSHA Form 300A Annual Summary is not altered, defaced, or covered by other material. The document must be posted no later than February 1st of the year following the year covered by the records and it must be kept posted until April 30th.
Frequently Asked Question: Can OSHA Summary Form 300A be posted electronically (on our intranet website) to satisfy the Feb 1-Apr 30 posting requirement?
Answer: No. A paper copy of the Form 300A must be posted in a conspicuous place or places where notices to employees are customarily posted. See our OSHA Quiz “Can You Post Your OSHA Form 300-A Electronically?” for more on this topic.
Frequently Asked Question: I posted the OSHA Form 300A in our company break room. I have received new information about an accident that occurred on December 20 that will extend the restricted days to the full 180 max count. Do I need to fill out a new OSHA Form 300A or can I just update the current form that is posted?
Answer: You are not required to update the 300A Annual Summary, although you may update the form if you wish to do so. However, you must update the OSHA Form 300 to reflect the new information.
Retention and Update Period Requirements for the OSHA Form 300A
OSHA requires the employer to retain the completed OSHA Form 300A for a period of five (5) years following the end of the calendar year that these records cover. While OSHA requires the employer to update the OSHA Form 300 during the five year storage period, you are not required to update the OSHA Form 300A Annual Summary, but you may do so if you wish.
Frequently Asked Question: Does the OSHA Form 300A Summary page that was posted need to be submitted to OSHA directly as well as posted?
Answer: Keep the form on file at your establishment for the 5 year retention period.
Click here to read our article on the Top 10 Most Common Mistakes we see in completing the OSHA Form 300A