Don’t Forget to Post OSHA Injury and Illness Data at Your Worksite
Employers who are covered by the Occupational Safety and Health Administration's (OSHA's) record-keeping rule must post a summary of 2018 work-related injury and illnesses in a noticeable place from Feb. 1 to April 30. Read this blog post from SHRM to learn more.
Employers that are covered by the Occupational Safety and Health Administration's (OSHA's) record-keeping rule must post a summary of 2018 work-related injury and illnesses in a noticeable place from Feb. 1 to April 30. Here are some compliance tips for employers to review.
Required Posting
Many employers with more than 10 employees—except for those in certain low-risk industries—must keep a record of serious work-related injuries and illnesses. But minor injuries that are treated only by first aid do not need to be recorded.
Employers must complete an incident report (Form 301) for each injury or illness and log work-related incidents on OSHA Form 300. Form 300A is a summary of the information in the log that must be posted in the worksite from Feb. 1 to April 30 each year.
"This information helps employers, workers and OSHA evaluate the safety of a workplace, understand industry hazards, and implement worker protections to reduce and eliminate hazards," according to OSHA's website.
Employers should note that they are required to keep a separate 300 log for each "establishment," which is defined as "a single physical location where business is conducted or where services or industrial operations are performed."
If employees don't work at a single physical location, then the establishment is the location from which the employees are supervised or that serves as their base.
Employers frequently ask if they need to complete and post Form 300A if there were no injuries at the relevant establishment. "The short answer is yes, " said Tressi Cordaro, an attorney with Jackson Lewis in Washington, D.C. "If an employer recorded no injuries or illnesses in 2018 for that establishment, then the employer must enter 'zero' on the total line."
Correct Signature
Before the OSHA Form 300A is posted in the worksite, a company executive must review it and 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," according to OSHA.
A common mistake seen on 300A forms is that companies forget to have them signed, noted John Martin, an attorney with Ogletree Deakins in Washington, D.C.
There are only four company representatives who may certify the summary:
- An owner of the company.
- An officer of the corporation.
- The highest-ranking company official working at the site.
- The immediate supervisor of the highest-ranking company official working at the site.
Businesses commonly make the mistake of having an HR or safety supervisor sign the form, said Edwin Foulke Jr., an attorney with Fisher Phillips in Atlanta and Washington, D.C., and the former head of OSHA under President George W. Bush.
They need to get at least the plant manager to sign it, he said, noting that the representative who signs Form 300A must know how numbers in the summary were obtained.
Once the 300A form is completed, it should be posted in a conspicuous place where other employment notices are usually posted.
Electronic Filing
The Improve Tracking of Workplace Injuries and Illnesses rule requires covered establishments with at least 20 employees to also electronically submit Form 300A to OSHA.
Large establishments with 250 or more employees were also supposed to begin electronically submitting data from the 300 and 301 forms in 2018, but the federal government recently eliminated that requirement. However, those establishments still must electronically submit their 300A summaries.
The deadline to electronically submit 2018 information is March 2.
SOURCE: Nagele-Piazza, L. (1 February 2019) "Don’t Forget to Post OSHA Injury and Illness Data at Your Worksite" (Web Blog Post). Retrieved from https://www.shrm.org/resourcesandtools/legal-and-compliance/employment-law/pages/don%E2%80%99t-forget-to-post-osha-injury-and-illness-data-at-your-worksite.aspx/
Don’t Miss the February 1st Deadline for Posting Your OSHA Injury/Illness Summary Form
Originally posted on January 28, 2015 by Laura Kerekes on www.thinkhr.com
It’s that time of year to look back on your workplace illnesses and injuries for 2014, ensure that you have recorded the correct information in your OSHA logs, and post the information in your workplace starting February 1, 2015. Do you need to comply with this posting requirement, even if you’ve had no injuries or illnesses this past year? You probably will need to comply — most employers do.
Employers are responsible for providing a safe and healthful workplace for their employees. The role of the Occupational Safety and Health Administration (OSHA) is to assure the safety and health of workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health. Employers are required to have a Workplace Injury and Illness Prevention Program in place, with active monitoring of results. The intent of the OSHA log reporting is to summarize the year end results and focus both employers’ and employees’ attention on workplace safety so that everyone can make safety a top company priority.
Do you need to comply with the February 1st deadline?
If you had 10 or more employees at all times during 2014, you will need to comply, unless your company’s Standard Industrial Classification (SIC) Code is included in the industry list of exclusions available at https://www.osha.gov/oshstats/naics-manual.html.
What You Should Do
Assuming that your business does not fall under the exclusions of OSHA reporting, you’ll need to ensure that two OSHA forms are completed fully, the Form 300 (log) and the Form 300A. Both forms and the instructions can be accessed here.
Form 300: This form is used to record all injuries and illnesses, except those that required first aid only. This form is not posted due to privacy considerations. There are certain injuries and illnesses where you do not include the employee’s name for privacy (sexual assaults, HIV infection, etc.), and an employee may request that his or her name not be entered on this log.
Form 301 (do NOT post): This form allows you to record more data about how the injury or illness occurred. As with Form 300, this form is not posted due to privacy considerations. Employee representatives, however, may have access to this form but only the portion that contains no personal information.
Form 300A: This is the form that must be completed and posted beginning February 1st through April 30th. It contains a summary of the total number of job-related injuries and illnesses that occurred during the previous year that were logged onto the Form 300. Information about the annual average number of employees and total hours worked during the calendar year is required for calculating incidence rates. Companies with no recordable injuries or illnesses in the previous year must post the summary with zeros on the “total” line. A company executive must certify all establishment summaries. Employers are required only to post the summary Form 300A, not the Form 300 log.
Form 300A must be displayed in a common area where notices to employees usually are posted. Employers must make a copy of the summary available to employees who move from worksite to worksite, such as construction workers, and employees who do not report to any one office on a regular basis.
More information regarding OSHA’s recordkeeping rule can be found in the OSHA Fact Sheet.
