Starting February 1, employers required to keep and maintain an OSHA 300 injury and illness log must post a summary of the total number of job-related injuries and illnesses that occurred during the previous year.
According to the Occupational Safety and Health Administration (OSHA), employers are only required to post the summary (OSHA Form 300A) – not the OSHA 300 Log – from Feb. 1 to April 30, 2018.
Under the federal Occupational Safety and Health Act (OSH Act), employers subject to the record-keeping requirements must indicate the total number of job-related injuries and illnesses that occurred last year in the OSHA Form 300A.
Key Points for Compliance
If you are required to post the work-related tally of injuries and illnesses, keep in mind the following:
- You are required to post it whether or not you had any injuries in the previous year. If there has been no incidence of injuries or illnesses reported, it is appropriate to indicate that you had no injuries or illnesses.
- Sign the 300A when you post it.
- A company executive must certify that he or she has examined your OSHA Form 300, log of work-related injuries and illnesses, and that he or she reasonably believes that the OSHA Form 300A is correct and complete.
- You are required to post the 300A summary sheet in work areas where employee notices are usually placed. The aim is to raise awareness among employees about the injuries and illnesses occurring in the workplace.
Who are Exempted from Compliance
If you are an employer, you must be familiar with the Recordkeeping Rule that mandates employers to maintain an OSHA 300 Log of serious injuries and illnesses. The OSHA requirement enforces employers to post a 300A in their workplace on the first of February encompassing all injuries and illnesses that were recorded the prior year.
As most employers know, there are also some exemptions that apply to these requirements, namely:
Employers in certain low-hazard industries are eased off from the requirements of the rule.
Back in 1982, there was a very broad list of these exempted low-hazard industries, spanning the finance, insurance, and real estate sector among many others.
There was a shift to the exemption onto a list based on Standard Industrial Classification (SIC) and Bureau of Labor Statistics (BLS) data from the late 1990s.
In 2015, however, OSHA then released a set of new guidelines for which businesses could claim the exemption. The North American Industry Classification System (NAICS) codes was used by the 2015 guidelines to identify which industries are exempted from the rule.
We recommend to always check whether your business is exempt from the rule by using the NAICS webpage to determine your NAICS code.
Employers with Ten or Fewer Employees
This is the second exemption to the compliance from the requirements of the rule. However, there are some misconceptions that need to be addressed to avoid further confusion.
Our tip is to just remember these things:
- The employers who are exempted from the requirements of the rule are those who had 10 or fewer employees ‘at all times during the previous calendar year.” This means, once you had 11 (or more) people at any time during the year working for you – even if your current number of staff is back down to 10 or fewer – your company cannot claim this exemption to apply to you.
- Facility size is not factored in the exemption but the company size only. thus, when your company employs 1,000 employees that has several small facilities with fewer than 10 employees each, each would still need to have those small facilities post a 300A. A franchise business with very small individual locations would be a good example of a company in this situation.
Another important pointer to keep in mind is that starting July 1 last 2017, OSHA requires businesses with 250 or more employees and businesses with 20-249 employees in certain high risk sectors, to submit their Form 300A information online. Based on the final rule issued by OSHA, this new requirement is aimed at improving workplace injury and illness tracking.
Through the year, OSHA has been beefing up the set of OSHA rules, further expanding the list of work-related accidents that employers are required to report, regardless of the size of their business or their industry.
OSHA believes that changes it adopted will further improve its ability to identify hazards in the workplace and prevent serious injuries and fatalities.
Do you need help getting your OSHA record-keeping requirements where it needs to be? PCS Consultants, Inc. can help you meet OSHA requirements while taking the necessary steps to ensure utmost safety in your workplace! Visit our OSHA Requirements Compliance and Management Solution pages to learn more.
For more information on the OSHA Form 300A requirement, visit their record keeping page. Click Here