OSHA 300A Forms Must Be Posted by February 1
Every employer subject to the Occupational Safety and Health Act law (OSHA) must post the OSHA Form 300A by February 1, 2019.
That means the employer (probably the safety officer and/or HR) needs to gather up the data on all OSHA-reportable workplace injuries from the prior year. Make sure that the number of cases on the top of the form and the injury and illness types on the bottom of the form are the same.
And once it is ready to be posted, the form must be signed by a company executive who is either an owner of the company, an officer of the corporation, the highest-ranking company official working at that establishment, or the immediate supervisor of the highest-ranking company official.
The Form 300A is the document an employer uses to report the summary of the total number of job-related injuries and illnesses that occurred the prior year and that the company reported on its OSHA Form 300 throughout the year.
The Form 300A summary includes an employer’s total number of deaths, missed workdays, job transfers or restrictions, and injuries and illnesses. It also includes the number of workers and the hours they worked for the year.
Although not posted, the OSHA form 300 must be available for inspection by employees as per federal law. And while many employers have expressed concern about access by employees to the Form 300 due to medical privacy concerns, OSHA continues to advise that the information should be available.
The OSHA forms 300 and 300A are available from the OSHA website at www.osha.gov
If a company recorded no injuries or illnesses in 2018, the employer must enter "zero" on the total line.
Employers with 10 or fewer employees and employers in certain industries are normally exempt from federal OSHA injury and illness recordkeeping and posting requirements.
Employers covered by OSHA should know that all accidents that result in one or more fatalities or in the hospitalization of three or more employees must be reported verbally within eight hours to the nearest OSHA office.
Generally, only serious injuries that are the result of workplace activity should be included on the 300A. That means an employer should always ascertain whether the injury or illness was due to work duties.
A serious injury is one that results in a fatality, loss of consciousness, days away from work, a restricted work schedule or job transfer, or a significant injury or illness diagnosis by a health-care provider, or that requires medical treatment beyond basic first aid. Incidents that only require first aid should not be reported.
If the injury involved is of a sensitive nature, such as sexual assault, then employers should write “privacy case” in the box for the worker’s name.
Companies are required to update and maintain records for five years plus the current year and provide them to OSHA investigators for inspection, if requested.
If you have any questions about how to complete the 300A form or what is a reportable event, please visit the OSHA Web site.
Here are the most common mistakes that employers make on OSHA reporting:
- Failing to post the OSHA 300A because the company is unaware of the posting requirement;
- Failing to post the OSHA 300A because the company had no OSHA-recordable injuries;
- Failing to post the OSHA 300A in a conspicuous location;
- Posting the OSHA 300 log instead of the 300A Summary form;
- Failing to complete the information about the company (NAICS) or employment information (i.e., average number of employees, hours worked);
- Failing to have the form signed;
- Having the wrong person sign the form; and
- Posting one OSHA 300A for multiple facilities instead of at each facility.
Members may contact the AIM Employer Hotline at 1-800-470-6277 with questions about this or any other HR-related matter.