Safety Tidbit 4.24 - It's Time to Post the 300A but Why?

Safety Tidbit 4.24 – It’s Time to Post the 300A but Why?

Reference:       OSHA Recordkeeping Standard 1904

                        1/25/2019 Amendment for electronic tracking of injuries and illnesses

Well, it’s that time again. If you have 11 or more employees (full and part-time) at any time during the year [1904.1(a)] you must record certain injuries and illnesses.  Now, you may be in an industry that is partially exempt from keeping the records if your industry is listed in Appendix A of 1904 Subpart B. Many of these industries are considered “low risk” as they have a low incidence of injury. But that is the topic for a future Safety Tidbit.

So you have established that your company must keep the records and therefore you must post a summary of activity. However, first, you must review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any deficiencies identified [1904.32(a)(1)]. Second, you create an annual summary of injuries and illnesses recorded on the OSHA 300 Log [1904.32(a)(2)]. And third, you must certify the summary as accurate by signing it.

First question: Who must certify the annual summary to ensure it is accurate and take responsibility for the injuries that happened during the previous year?  OSHA requires one of the following sign the summary [1904.32(b)(4)(i-iv)]:

·      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

·      the immediate supervisor of the highest-ranking company official working at the establishment.

Second question: Why must the Summary be posted from February 1 until April 30^th? You must post a copy of the annual summary in each establishment in a conspicuous place or places where notices to employees are customarily posted. You must ensure that the posted annual summary is not altered, defaced or covered by other material [1904.32(b)(5)].  Ultimately, posting is to allow sufficient time for all employees to review the summary, ensure its accuracy, and make corrections if necessary.

Note: On 1/25/2019, OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have a new safety or health question, please let me know.