Date: Apr 09, 2013

As a reminder, most employers with more than 10 employees are required to record workplace injuries and illnesses pursuant to OSHA's recordkeeping standard using OSHA Form 300A. This is a summary log of all work-related injuries and illnesses that occurred at your place of business in 2012. The posting period is from February 1, 2013 through April 30, 2013. The form is available for downloading from the OSHA website. Employers with 10 or fewer employees are exempt (unless they have a fatality, which must be reported).

The summary should contain the total numbers of job-related injuries and illnesses that occurred in 2012 and were logged on the OSHA 300 form. Employment information regarding the annual average number of employees and total hours worked during the calendar year is needed to calculate incidence rates. Even if there were no recordable injuries or illnesses in 2012, employers are still required to post the form with zeros on the total line. The summary log must be posted in common areas where employees have access, typically where other safety information and internal notices are displayed. Copies must also be made available to employees who may not see the posted summary because they may not report to a fixed location on a regular basis.

The recordkeeping standard also requires a certification of the 300A logs by a “company executive.” According to OSHA regulations, only the following management officials qualify as a “company executive”: 1) an owner of the company; 2) an officer of the corporation; 3) the highest ranking company official working at the establishment; or 4) the immediate supervisor of the highest ranking company official working at the establishment. This means that HR managers or safety directors normally cannot sign the OSHA 300A summary unless they are an officer of the company.

Before the annual summary is prepared, the recordkeeping rule imposes an express duty on the employer to review the Log (Form 300) to verify entries are complete and accurate. An employer has a duty to update and maintain records for five years plus the current year and provide them for inspection by OSHA investigators.

WG Staff Contact

Jason Resnick
Sr. Vice President & General Counsel

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