Compliance Alert: OSHA Form 300A Must Be Posted by February 1

Reminder: OSHA Form 300A Must Be Posted by February 1
The Occupational Safety and Health Administration (OSHA) mandates that all employers who are required to maintain the OSHA 300 Log of Work-Related Injuries and Illnesses post a summary of the previous calendar year’s log between February 1 and April 30 of each year, even if no incidents occurred in the preceding calendar year. The summary (OSHA Form 300A) must be certified by a company executive and posted in a conspicuous location where notices to employees are customarily posted.

All employers who had 11 or more employees at any point during the last calendar year are covered by this requirement unless they qualify as part of an exempt low-risk industry. This count is based on the number of employees in the entire company, not per establishment. A full list of the industries that are exempt from OSHA routine recordkeeping requirements, listed by North American Industry Classification System codes (NAICS), can be found here.

The OSHA Log of Work-Related Injuries and Illnesses (Form 300), Summary (Form 300A), and Instructions can be found in the Forms section of the HR Support Center by searching for OSHA Form 300. Click the link that says, “OSHA Form 300, 300A, 301, and Instructions.” The documents can also be downloaded from OSHA directly here.

If your workplace is currently closed because of COVID-19 and you are unable to post the log there, we recommend posting it on a company intranet page, bulletin board, or other location online where it can be easily seen and accessed by employees. If you return to the workplace before April 30, you should also physically post it at that time.

Form 300A Electronic Submission Required for Certain Employers by March 2
Employers must send their Calendar Year 2020 Form 300A data to OSHA if they have 250 or more employees or have 20–249 employees and are in certain high-risk industries. Employers must use OSHA’s online Injury Tracking Application (ITA). The deadline to submit the report is March 2, 2021.

Employers that meet any of the following criteria DO NOT have to send their information to OSHA:

• Employers that are exempt from OSHA’s routine recordkeeping requirements, as mentioned above.
• Employers that never had 20 or more employees during the previous calendar year, regardless of industry.
• Employers that had between 20 and 249 employees at some point during the previous calendar year but are NOT on this list of high-risk industries.

The electronic reporting requirements are based on the size of the establishment (how many employees are at the physical location), not how many employees are in the entire company.

Employers that are required to send their Form 300A to OSHA must submit injury and illness data in the ITA online portal, even if the employer is covered by a State Plan that has not completed adoption of their own state rule.

Additional information, FAQs, and the Injury Tracking Application can be found on OSHA’s site, here.

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