I have not seen anything indicating that the government shut down has stayed the obligation to prepare and post the OSHA 300A forms. So, for employers who are covered by OSHA’s recordkeeping rule, it almost time to prepare and post the OSHA Form 300A, “Summary of Work-Related Injuries and Illnesses,” (Post by February 1 and keep posted until April 30.) The requirement of completion, certifying, and posting the 300A Form is distinct from the electronic data submission requirement of OSHA’s new Electronic Recordkeeping Rule. Employers should not confuse submission of injury and illness data to OSHA electronically with the requirement of certifying and posting the 300A Annual Summary Form.
Be sure to comply with the details of completing the 300A Form. Prior to posting, a company executive must review the Form and certify that “she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.”
A company executive can be one of the following: (1) an owner of the company (only if the company is a sole proprietorship or partnership); (2) an officer of the corporation; (3) the highest ranking company official working at the establishment; or (4) the immediate supervisor of the highest ranking company official working at the establishment.
Don’t hesitate to call me directly if you have any questions.
Written By: Jerry Stovall, Jr.