February 1 is the deadline for annual posting of the OSHA 300A summary of workplace injuries and illnesses. Attorney Eric J. Conn, chair of the Conn Maciel Carey OSHA practice group, emphasizes in the firm’s OSHA Defense Report blog that the annual requirement should not be confused with OSHA’s new electronic recordkeeping rule.
“The February 1st deadline is only about the internal posting of 300A data for your employees’ eyes,” he writes. The electronic recordkeeping rule is a new requirement for certain employers to submit the annual summary forms through an electronic portal.
According to Conn, employers commonly make the following four mistakes with the 300A:
- Not having an internal management representative with adequate status certify the 300A.
- Not posting a 300A for years in which there were no recordable injuries.
- Not maintaining a copy of the certified version of the form.
- Not updating prior years’ 300 logs based on recent information about previously unrecorded injuries or changes to injuries that were previously recorded.
Those who certify the forms attest that they:
- Personally examined the 300A;
- Personally examined the OSHA 300 log from which the summary was developed; and
- Reasonably believe, based on their knowledge of recordkeeping processes, that the 300A summary is correct and complete.
Conn reminds employers that the 300A must remain posted where employee notices are typically posted, and remain there for at least three months, through April 30. Once the summary comes down, it must be maintained for 5 years following the end of the prior calendar year at the facility covered by the form or at a central location. In addition to the summary, you need to save the 300 log on which it was based and any corresponding 301 incident report forms.