It’s once again time to meet OSHA’s record keeping requirement mandating that all covered employers post a summary (300A Summary) of its prior year’s work-related injuries and illnesses by February 1 and it must be posted in a location visible by employees until April 30.
This applies to all nonexempt employers with more than 10 employees. Exempted employers are those identified as operating in lower hazard industries. If you are not sure if you are exempt, check the North American Industry Classification System (NAICS) to determine which industries and employers are exempt.
Even if as an employer your industry is exempt, it still must comply with the recordkeeping requirements if OSHA or the Bureau of Labor Statistics has informed you that it is required to keep a log and post a summary despite the industry exempt status.
The 300A summary is derived from your company’s OSHA 300 log (Work-Related Injuries and Illnesses). Only serious work-related injuries must be recorded on the log which includes injuries resulting in a death, loss of consciousness, days away from work, a restricted work schedule or job transfer, or a significant injury or illness diagnosis by a health care provider, or injuries/illnesses that require medical treatment beyond basic first aid.
The 300A summary must be certified by a company executive or an officer of the company. This executive must certify that he or she has reviewed the related records and that the posted summary is accurate and complete, to the best of his or her knowledge.
Finally, OSHA implemented updates to its recordkeeping and reporting rules that were effective in January 2015. In light of these updates, and OSHA’s recent focus on recordkeeping issues, the February 1 deadline is a good time for all covered employers to review their policies and procedures for complying with the recordkeeping and reporting regulations.
Source: Burns & Levinson LLP – Mary Kate Geraghty
Source: Industry News
