Date: Jan 28, 2014

As a reminder, employers covered by the Occupational Safety and Health Administration's (OSHA) injury and Illness Recordkeeping Rules are required to post an OSHA Form 300A.  This is a summary log of all work-related injuries and illnesses that occurred at your place of business in 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 2013 that 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 2013, 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. Also copies must 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 form must be posted between February 1 and April 30, 2014.

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 that entries are complete and accurate. Employers should carefully review their 2013 records before certifying and posting them on February 1, 2014. For more information, contact WG’s Jason Resnick at (949)885-2253.

WG Staff Contact

Jason Resnick
Sr. Vice President & General Counsel

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