OSHA Form 300A Posting Requirements Begin Feb. 1
The Occupational Safety and Health Administration (OSHA) requires employers subject to its recordkeeping requirements to post copies of their OSHA Form 300A between Feb. 1 and April 30 of each year.
The OSHA Form 300A, also known as the “Summary of Work-related Injuries and Illnesses,” must be completed by Feb. 1 using data from the previous calendar year.
As a reminder, OSHA’s recordkeeping requirement does not apply to employers with 10 or fewer employees, or to employers that are in a partially exempt industry.
Severe Injury Reporting
Employers must report any worker fatality within eight hours and any amputation, loss of an eye or hospitalization of a worker within 24 hours. For all COVID-19 related illnesses the emergency temporary standard provides the reporting time frames for when to report a death or inpatient hospitalization.
Employer Action Steps
On Feb. 1, employers subject to OSHA recordkeeping requirements must ensure that copies of their completed Forms 300A are posted in each of their establishments. The form must be displayed in a conspicuous place or places where notices to employees are customarily posted.
Until April 30, these employers must also ensure that their Form 300A postings remain in place and are not altered, defaced or covered by other material.
OSHA Electronic Reports Are Due March 2
Each year, the Occupational Safety and Health Administration (OSHA) requires certain employers to submit information from their OSHA Form 300A electronically. Affected employers must submit their reports using OSHA’s Injury Tracking Application (ITA).
Affected establishments include:
- Establishments with 250 or more employees, if they are already required to create and maintain OSHA records; and
- Establishments with between 20 and 249 employees that belong on a high-risk industry.
OSHA or the Bureau of Labor Statistics may require otherwise exempt establishments to submit these reports on a special, case-by-case basis.
OSHA will collect information on injuries and illnesses to identify emerging hazards, characterize specific areas of concern, or target inspection and outreach initiatives under OSHA’s emphasis program.
Establishment Size
Coverage under the electronic reporting rule applies to establishments, not employers. An employer may have several worksites or establishments. In these situations, some establishments may be affected while others are not.
To determine whether an establishment is affected, employers must determine each establishment’s peak employment during the calendar year and must count every individual that worked at that establishment, regardless of whether he or she worked full-time, part-time, or was a temporary or seasonal worker. A firm with more than one establishment may submit establishment-specific data for multiple establishments.
This Legal Update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2022 Zywave, Inc. All rights reserved.