22 Jan Reminder – Post your OSHA 300 Log

Post your OSHA 300 Log

All employers required to maintain the Occupational Safety and Health Administration’s 300 Logs for workplace injuries and illnesses must post their 2013 annual summary by February 1, 2014, utilizing the annual summary form (form 300A). you can get this form on the OSHA website at www.osha.gov. You need to do this even if you don’t have a recordable illness or injury. The direct download is here: http://www.osha.gov/recordkeeping/new-osha300form1-1-04.xls

Here are some additional details that are frequently misunderstood or overlooked and which could result in OSHA citations.

Executive Certification

OSHA’s record-keeping standard needs to be certified by an executive. OSHA has determined an executive to be 1) Company Owner; 2) Officer of the Corporation; 3) Highest Ranking Official, or 4) Immediate Supervisor of the Highest Ranking Official.

Number Of Employees And Hours Worked

This yearly prerequisite requires employers to include the average (annually) number of hours worked by their employees. This is made to help compare the frequency of injuries and illness from one workplace to another

Posting Period

The posting period is for three months; February 1^st to April 30^th. The 300A summary must be posted in each establishment in a conspicuous place or places where notices to employees are customarily posted. You must provide copies of the 300A summary to any employee who may not see the posted summary because they do not report to a fixed location on a regular basis.

Record Review

Before the annual summary is prepared, the record-keeping rule imposes an express duty on the employer to review the Log (form 300) to verify that entries are complete and accurate. Employers must review the records as “extensively as necessary” to ensure their accuracy. Do take time to review the forms for technical errors as well as to review accident reports and other materials, and ensure that all recordable incidents have been included.

An employer has a duty to update and maintain records for five years plus the current year and provide them for inspection by OSHA investigators.

Finally, employers are under a duty to ensure that the posted annual summary is not altered, defaced or obscured during the entire posting period.