As we approach the end of January, I would like to remind our members that the OSHA 300A Form posting deadline is approaching. The OSHA Record Keeping Rule requires employers keep records of all work related injuries and illnesses. This includes the OSHA 300, 300A and 301 forms that employers must have on file. If you do not already have a copy of these forms, they can be accessed through this link OSHA Recordkeeping Forms and Instructions. The 300A Summary of Injuries and Illnesses is the only form that must be posted from Feb. 1 to April 30 of each year. The 300A must be posted in a common area where notices to employees would normally be posted. Be sure to post this form containing work related injury and illness data from calendar year 2023 beginning on February 1, 2024.
It is very important that the OSHA 300A Summary be filled out completely and correctly. In the case that there were no work-related accidents to report, the form must be filled out with zeros in each blank. Often the establishment information is also overlooked and or just not signed. One area of the establishment information that creates some confusion is the area asking about average number of employees and total hours worked. The average number of employees is simply the total number of paychecks written divided by the number of pay periods. This should include all full-time, part-time, temporary, migrant, salaried, and hourly employees.
The other form found at the link above is the OSHA 300 Log of Work-Related Injuries and Illnesses. This is a log containing information about every work-related death and almost every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, and/or medical treatment beyond first aid. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. It is also important to completely fill out the OSHA 300 form. All columns must be totaled even if you had no accident to reports there must be a zero for a total. The information from the OSHA 300 form is used to complete the OSHA 300A form.
This is also a good time to enter your 2023 injury and illness data on the OSHA Web Portal. Any employer with 20 or more employees at any time during the calendar year is required to enter this data electronically. The data entered electronically is essentially the same data contained in the OSHA 300A form. The deadline for electronic submission is March 2, 2024. To access the electronic submission portal simply click this link OSHA Electronic Submission Page
Hopefully, this article will serve as a reminder of what must be reported and posted to be in compliance with OSHA’s Recordkeeping Standard. If OSHA comes to your facility, they will ask to see these forms going back for a period of 5 years. It is important to have the files and data on hand and easily accessible. More information regarding OSHA Recordkeeping can be accessed through OSHA Recordkeeping Rule as well as the 2020 Southeastern Cotton Ginners Safety Reference Manual.