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HR MATTERS E-TIPS
THIS WEEK’S E-TIP:
OSHA Form 300A Must Be Posted Next Week
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THIS WEEK’S E-TIP:
OSHA Form 300A Must Be Posted Next Week
February is just around the corner which means that you have just a few
days to make sure your OSHA annual summary of work-related illnesses
and injuries is ready to be posted. |
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THIS WEEK’S E-TIP:
OSHA Form 300A Must Be Posted Next Week
Are you ready to post your Occupational Safety and Health
Administration (OSHA) Form 300A? Covered employers are required to
post the form, a Summary of Work-Related Injuries and Illnesses,
from
February 1 until April 30 each year. Form 300A reports your total
number of deaths, missed workdays, job transfers or restrictions,
and
injuries and illnesses as recorded on Form 300 (the Log of
Work-Related
Injuries and Illnesses). Form 300 must be maintained throughout the
year. Forms 300A and 300 are two of three OSHA forms required as
part of the agency’s recordkeeping rule.
Of course, all employers covered by the Occupational Safety and
Health
Act (the OSH Act) also must post a notice informing employees of the
Act’s protections and obligations. The notice must be posted in a
conspicuous place or where notices to employees are customarily
posted. (Download
free Employee Safety model policy and supporting background
information.)
General OSHA Recordkeeping Requirements
OSHA requires employers with 11 or more employees, except employers
in certain low-hazard industries, to maintain a log and summary of
all
“recordable” occupational injuries and illnesses. Employers in 56
low-
hazard retail, service, finance, insurance, and real estate
industries are
exempt from this recordkeeping. These industries are specifically
listed
by Standard Industrial Classification (SIC) code in Appendix A of
the
OSHA recordkeeping regulations.
An injury or illness is considered “recordable” if it meets the
following
three criteria:
(1) It is work-related. An injury or illness is considered 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
preexisting injury or illness. See 29 C.F.R. §§1904.4, 1904.5(a).
(2) It is a new case. An injury or illness is considered to be a new
case if: (a) the employee has not previously experienced a recorded
injury or illness of the same type that affects the same part of the
body;
or (b) the employee previously experienced a recorded injury or
illness of
the same type that affected the same part of the body but had
recovered
completely and an event or exposure in the work environment caused
the signs and symptoms to reappear. See 29 C.F.R. §§1904.4,
1904.6(a).
(3) It results in any of the following: death, days away from work,
days
of restricted work or transfer to another job, medical treatment
beyond
first aid, loss of consciousness, or diagnosis by a physician or
licensed
health care professional as “significant.” See 29 C.F.R. §§1904.4,
1904.7.
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An occupational injury or illness is also recordable if it involves:
(1) a
needlestick or sharps injury; (2) medical removal under an OSHA
standard; (3) certain occupational hearing loss; or (4) work-related
tuberculosis. See 29 C.F.R. §§1904.8-1904.11.
The regulations provide two forms for recording the required
information,
OSHA Forms 300 (the Log of Work-Related Injuries and Illnesses) and
300A (the Summary of Work-Related Injuries and Illnesses). You also
must maintain a supplementary record for each recordable injury or
illness on Form 301 (Injury and Illness Incident Report). Forms 300,
300A, and 301 should be maintained on a calendar year basis. |
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What Form 300A Reports
Form 300A is intended to summarize your yearly totals for
illnesses and
injuries and is taken from the information recorded on Form 300.
It
requires that you calculate the total number of deaths, cases
with days
away from work, cases with job transfers or restrictions, and
any other
recordable cases. In addition, you must identify the total
number of days
of job restrictions or transfers and days away from work.
Finally, you
must report what injuries and illnesses you experienced,
including the
total number of injuries, skin disorders, respiratory
conditions,
poisonings, hearing loss, and all other illnesses.
Where to Post Form 300A
You must post a copy of Form 300A in each work establishment in
a
conspicuous place or places where notices to employees are
customarily
posted, such as in employee break areas or locker rooms. You
also
must ensure that the posted annual summary is not altered,
defaced, or
covered by other material. And finally, an executive must
certify that the
OSHA 300 Log has been examined and that the annual summary is
believed to be correct and complete. The certifying executive
can be
either the owner or an officer of the organization, the
highest-ranking
executive at the establishment, or the supervisor of that
highest-ranking
executive. (Download
free Employee Safety model policy and supporting
background information.)
Forms and Assistance Available from OSHA
OSHA provides information on its recordkeeping and posting
requirements on its Web site at
http://www.osha.gov/recordkeeping/index.html. There you will
find
Frequently Asked Questions on the requirements, as well as the
“OSHA
Recordkeeping Handbook” and the recordkeeping forms. The most
recent forms are dated as revised in January 2004. |
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Subscribers to the
Personnel Policy Manual and HR Policy Answers on
CD can find more information on OSHA’s posting and recordkeeping
requirements in Employee Safety, Chapter 601, notes 19 and 21.
Not a subscriber? If you would like to order one of our policy
chapters,
go to:
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happy to help you. |
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