In general, employers with 10 or more employees are required to post in the workplace a completed OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) every year between February 1 and April 1. Employers with fewer than 10 employees and certain low-risk industries are exempt from this requirement. (Click here for a list of partially exempt industries.) On February 1, 2019, covered employers must post OSHA Form 300A for injuries and illnesses that occurred in 2018. Employers must post OSHA Form 300A even if they had no recordable injuries or illnesses in 2018. Posting is required by 29 CFR § 1904.32. (Read the rule here.) OSHA injury and illness recording forms are available here.
What Data is Summarized on OSHA Form 300A?
OSHA Form 300A summarizes the employer’s work-related injuries and illnesses for the prior year, including the number of cases, days away from work, and general types of illnesses or injuries. The Summary is prepared using the data recorded on the employer’s OSHA Form 300 (Log of Work-Related Injuries and Illnesses). An injury or illness must be recorded on OSHA Form 300 if it results in:
- death
- loss of consciousness
- days away from work
- restricted work or transfer to another job
- medical treatment beyond first aid,
- any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
- cases that meet specified criteria involving needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.
Recordable injury or illness must be reported on the OSHA Form 300 Log within seven days. An employer is also required to fill out an OSHA Form 301 (Injury and Illness Incident Report) for each recordable work-related injury or illness. OSHA Forms 300 and 301 are completed throughout the year. OSHA Form 300A is completed after the end of the year.
Completing and Posting OSHA Form 300A
- Complete OSHA Form 300A by totaling each of the columns (G) through (M) on OSHA Form 300. The totals are recorded on the left side of OSHA Form 300A. If there were no recordable cases, zeros should be written in each column total.
- On the right side of the form, fill in the calendar year covered by the form. This year’s form covers calendar year 2018.
- Provide the name and address of the establishment, industry description, and NACIS classification (if known).
- Report the annual average number of employees covered by the OSHA 300 Log and the total hours worked by all employees covered by the OSHA Form 300 Log. OSHA provides worksheets to assist in these calculations.
- A company official must certify that the entries on the summary are true, accurate, and complete. The certifying official must be the owner of the company, an officer of the corporation, the highest-ranking company official at the establishment, or that person’s supervisor.
- Post OSHA Form 300A in each establishment in a conspicuous place or places where notices to employees are customarily posted. Employers must post hard copy of the form. Electronic posting will not suffice. Employers must ensure that the form is not altered, defaced or covered by other material.
- OSHA Form 300A must be posted no later than February 1 and may be removed on April 30. OSHA requires employers to retain the completed OSHA Form 300A for a period of five years.
Penalties for OSHA Posting Violations Increase
The penalties for OSHA posting violations have increased to $13,260, a $326 increase over last year. Civil penalties for OSHA violations are adjusted every year for inflation as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. Notice of the new penalty rates was published in the January 23, 2019 edition of the Federal Register.
Don’t Forget Upcoming Deadline to Report Electronically
In addition to physically posting OSHA Form 300A in the workplace, some employers are required to electronically submit to OSHA information from their 2018 OSHA Form 300A. This includes:
- establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and
- establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses
The deadline to electronically submit data from the 2018 OSHA Form 300A is March 2, 2019. Employers must use OSHA’s Injury Tracking Application (ITA) to report OSHA Form 300A information. (Click here to access the ITA portal.) Employers in most states covered by an OSHA-approved State Plan are also required to electronically submit to OSHA their injury and illness summary data.
If you have questions about completing any of OSHA’s recordkeeping forms, a brief tutorial is available here. Otherwise, give us a call. We’d be happy to help!