Employers should be aware of a major posting deadline that’s fast approaching, as the Occupational Safety and Health Administration (OSHA) has made clear in recent actions that it will continue to focus on record-keeping in 2014.
All employers required to keep Form 300, the Injury and Illness Log, must post Form 300A, the annual summary of job-related injuries and illnesses, in a workplace common area by Feb. 1, 2014. This year’s summary must include the total number of job-related injuries and illnesses that occurred in 2013. You can download the form here.
Form 300A reports a business’s total number of fatalities, missed workdays, job transfers or restrictions, and injuries and illnesses as recorded on Form 300. It also includes the number of employees and the hours they worked for the year. If there were no recordable injuries or illnesses, a company must still post the form, with zeroes on the appropriate lines.
Which Employers Must Track Illnesses and Injuries?
Nonexempt employers with more than 10 employees must track injuries and illnesses and post the form. Certain low-hazard industries are exempt. Businesses that employ fewer than 10 workers or those that fall into an exempt category must also record injuries if they are required to by OSHA or the Department of Labor’s Bureau of Labor Statistics for survey purposes.
Only the summary must be posted; the log does not have to be displayed but must be available to employees, their representatives or OSHA inspectors. Companies with multiple job sites should keep a separate log and summary for each location that’s expected to be operational for at least a year.
OSHA requires that a company executive certify the 300A summary. Company executives are defined as:
An owner of the company.
An officer of the corporation.
The highest-ranking company official working at the site.
The immediate supervisor of the highest-ranking company official working at the site.
This official 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.
HR managers normally cannot sign the OSHA 300A summary unless they are an officer of the company.
The 300A summary must be posted at each job site from Feb. 1 to April 30, in a conspicuous area where notices to employees are customarily placed. Copies of the form should be provided to any employees who may not see the posted summary because they do not regularly work onsite. Companies are required to update and maintain records for the current year and the following five years and provide them to OSHA investigators for inspection. Employers must also ensure that the annual summary is not altered, defaced or obscured during the posting period.
Generally, only serious injuries resulting from workplace activity must be reported. A business should review the employee’s activities to determine whether the injury is work-related. Businesses are not required to report injuries that stem from activities that are merely incidental to work responsibilities.
A serious injury is one that results in a fatality, 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 that requires medical treatment beyond basic first aid.
Employers should not report incidents that require only basic first aid.
If the injury is of a sensitive nature, such as sexual assault, then the employer should write “privacy case” in the box for the worker’s name.
OSHA requires companies to enter the average number of employees and the total hours they worked on the summary form. An employer can plug those figures into a formula to calculate injury and illness incidence rates and compare them with the data of other establishments in similar industries.
Roy Maurer is an online editor/manager for SHRM.
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