Risk Management Bulletin: Post OSHA 300A Summary by February 1st
REMINDER: It’s time to post the OSHA 2018 300A Summary in a conspicuous location!
It’s that time of year again! OSHA 300A summaries must be posted as of February 1st in a conspicuous location through April 30th. If you haven’t yet, double-check your 2018 OSHA 300 logs for accuracy—as companies often over/under report injuries and illnesses, which can have a negative impact. Failure to record required injuries and illnesses on your logs may result in OSHA citations with substantial penalties.
This bulletin will review steps in order to successfully complete the OSHA Form 300 Log as well as the OSHA 300A Summary.
Step 1: Determine the Establishment Locations
An OSHA Form 300 Log is required for each physical establishment location that is expected to be in operation for at least one year. OSHA considers the worker’s establishment to be a location to which an employee reports, receives direction or supervision, and collects pay.
Step 2: Identify Required Recordings
Work-related injuries and illnesses that result in the following must be recorded:
- Death, loss of consciousness, days away from work, restricted work activity, or job transfer.
- Medical treatment beyond first aid.
- Any work-related case involving cancer, irreversible disease, a fractured/cracked bone, or a punctured eardrum.
Step 3: Determine Work-Relatedness
When an accident occurs, employers must document a recordable injury/illness on the 300 log within seven days. An injury/illness is considered work-related and must be recorded on the log unless an exception applies. Some exceptions include:
- At the time of the injury or illness, the employee was at work as a member of the general public.
- The injury or illness surfaces while at work, but results solely from a non-work-related event or exposure.
- The injury or illness results solely from voluntary participation in a wellness program.
- The injury or illness is the result of eating or drinking or preparing food or drink for personal consumption.
- The injury is the result of an employee doing personal tasks outside of work hours.
Step 4: Complete OSHA Form 300
- Fill in the year, establishment name, city, and state.
- Assign each event a case number.
- Identify employee, employee’s job title, date of the injury/illness and location where the event occurred.
- Describe the event in detail, along with the parts of the body affected and the object/substance that directly injured or made the employee ill.
- Classify the case by choosing only one of the categories. The most serious outcome will need to be recorded; the employer should revise the log if the injury or illness progresses or the outcome is more serious than was originally recorded. The original entry must be crossed out, deleted, or concealed with correctional fluid.
- Enter the number of days the employee was on restricted work or job transfer, number of days away from work, or both.
- Identify whether the event is an injury or an illness.
- Total all columns at the end of the year.
Step 5: Complete and Post the OSHA 300A Annual Summary
The information from the OSHA Form 300 Log is then transferred to the 300A Summary by matching the corresponding lettered column on the log with the lettered blank space on the summary.
The employer must complete the establishment information section and have the summary signed by an authorized executive of the company. After completion, post the 300A summary form in the workplace from February 1 through April 30 of the year following the year in a conspicuous location.
Step 6: Electronic Submission
Employers with 20 or more employees who are subject to OSHA’s recordkeeping regulation must electronically submit to OSHA their information from Form 300A by March 2, 2019, deadline. https://www.osha.gov/injuryreporting/ita/
Employers with fewer than 20 employees at all times during the year do not have to submit information electronically to OSHA.
Step 7: Record Retention
The OSHA Form 300 Log and the OSHA 300A Summary must be kept for five years following the year that the log and summary pertain to.
Integrated Risk Solutions is available to assist you with any questions or concerns you may have. Please feel free to contact Matt Ingraham, firstname.lastname@example.org or by phone at 262-523-9600.