OSHA Form 300A Deadline Approaching

Author: Marta Moakley, XpertHR Legal Editor

January 26, 2015

Employers subject to the Occupational Safety and Health Administration's (OSHA) recordkeeping requirements must post Form 300A, Summary of Work-Related Injuries and Illnesses, by February 1. The form should remain posted until April 30.

This year, February 1 falls on a Sunday. As a result, employers that are not open for business over the weekend should post the form by Friday, January 30, 2015. The form must be conspicuously posted in each covered employer's workplace where notices are usually posted. A copy should be provided to employees who travel between worksites.

Most employers are subject to the recordkeeping requirements. However, employers with 10 or fewer employees and employers in certain low-hazard industries, such as retail, may not be subject to the requirements.

The Form 300A is a summary form. OSHA Form 300 is not a summary form, but should consist of an accurate and complete log of all injuries and illnesses that occurred in each establishment or worksite. Employers need not post the entire log as listed in Form 300, but only the summary contained in Form 300A.

Before posting the summary, OSHA requires that an executive examine the Form 300 log and certify that he or she has scrutinized it and reasonably believes the summary to be accurate.

OSHA defines an executive as one of the following:

  • An owner;
  • An officer;
  • The highest ranking official; or
  • The highest ranking official's supervisor.

The posting is required even if there were no injuries or illnesses to report for that year. Although the summary need only be posted through April 30, an employer must keep the log and summary (Forms 300 and 300A, respectively) for five years following the year to which they pertain.

OSHA may issue citations to employers that are not compliant with this recordkeeping requirement. Failure to comply with posting requirements may result in a penalty of up to $7,000.