Required Employers Must Post OSHA 300A Logs By Feb. 1

February 1 Through April 30 To Avoid Fines

 

Required employers must post their annual summary of work-related injuries and illnesses from last year on an OSHA Form 300A by February 1, 2015, and keep it openly posted in a common area for employees to see until April 30, 2015.

“Completing the required OSHA recordkeeping forms can be complicated for people who are not familiar with them, and in many instances, they are counterintuitive,” says Robert Box, Principal Consultant with Safety First Consulting in Georgetown, Texas.  To assist businesses in avoiding penalties from OSHA, Safety First Consulting is offering free information and consultations regarding OSHA’s Summary Form 300A during the month of February.

 

Nonexempt employers with more than 10 employees must track injuries and illnesses on the OSHA Form 300 and post the OSHA Form 300A in a conspicuous place to employees, even if there were no injuries in the previous year.  Certain low-hazard industries are exempt from this obligation (see which industries are exempthttps://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html).

 

Businesses that employ 10 or fewer workers for the entire previous year are exempt from OSHA’s recordkeeping rule for that year, but employers must include part time and temporary workers in the staff headcount. Only the 300A summary must be posted; the Form 300 log should not be displayed but must be available to employees, their representatives or OSHA inspectors. Companies with multiple workplaces should keep a separate log and summary for each location that is expected to be operational for at least a year.

 

This year’s summary must include the total number of recordable injuries and illnesses that occurred in 2014. The OSHA Summary Form 300A reports a business’s total year-end number of fatalities, missed workdays due to injury or illness on the job, job transfers or restrictions, and injuries and illnesses as recorded on the OSHA Form 300. It also includes the number of employees and the hours they worked for the year.  See all three OSHA recordkeeping forms (Forms 300, 300A, and 301) here https://www.osha.gov/recordkeeping/new-osha300form1-1-04-FormsOnly.pdf.

 

“If you’ve never had to keep a 300 log, it’s worth getting trained, reading through the recordkeeping standard and become an expert yourself, or getting help from a safety consulting company because it can be complicated for someone who doesn’t do this sort of thing all of the time,” Box recommended.  Employers can contact Safety First Consulting for free guidance at help@safetyfirstconsulting.com during the month of February.  Include company name, contact name, phone number and company address and Safety First Consulting will contact you to assist.

 

The list of industries that was traditionally exempt from keeping OSHA injury and illness records changed on January 1, 2015.  Newly covered employers who were previously exempt from OSHA record-keeping requirements and were not required to maintain the Form 300 in 2014 are not obligated to post the 300A on Feb. 1 of this year as the form relates to injuries from the prior year.  However, “employers who have never had to follow this rule in the past may not be aware that the OSHA 300 log must be updated within 7 calendar days of a recordable incident or be at risk of citation,” says Box.  Previously exempt employers should review the updated industry exemption list to see if they are now required to follow the rule.  Industries now required to follow OSHA’s recordkeeping rule are listed here https://www.osha.gov/recordkeeping2014/reporting_industries.html.  If a company is now required to keep records, they must maintain the OSHA 300 logs this year and post the OSHA Form 300A on February 1, 2016.

 

“Since OSHA’s recordkeeping standard can be confusing, many employers unintentionally under-report the number of injuries and illnesses on their logs,” says Box.  “If OSHA inspects a company’s operations, they will likely ask to see the 300 logs.   If the logs are filled out improperly, it will likely result in a citation.  Also worth noting, over-reporting injuries and illnesses may also result in citations.  A higher rate of incidents reported from a company’s workplace may trigger an OSHA inspection, where a citation would likely be issued for improper recordkeeping amongst other possible findings, so you have to know what you are doing with OSHA recordkeeping logs,” Box says.

Safety First Consulting helps businesses identify OSHA compliance deficiencies in their workplaces for less than the cost of one OSHA penalty, and can manage safety programs for businesses for less than half the cost of hiring a full time Safety Manager. In addition to offering custom written safety programs for companies, Safety First Consulting provides required safety training, industrial hygiene sampling, noise sampling, and workplace inspections.