Monday, January 28, 2019

The Annual OSHA February 1 Recordkeeping Deadline is Fast Approaching

Every year at this time the Occupational Safety and Health Administration (OSHA) requires employers with 10 or more employees to post the OSHA 300A form from February 1 to April 30th, 2019.  In addition, this year certain employers must electronically submit the OSHA 300A information directly to OSHA by March 2, 2019.  Last year, we did a webinar together with Keevily Spero & Whitelaw on completing the OSHA 300 & 300A form.  You can find the webinar here or watch it below.  


If you remember, the 300A form summarizes the injury and illness information that was kept on the OSHA 300 log form.  Covered employers are required to prepare and maintain records of serious occupational injuries and illnesses that occur at a workplace on the OSHA 300 log form.  At the end of the year, covered employers are required to tally the totals on each column and enter the totals on the OSHA 300A form.  The information should be used by employers to evaluate safety in the workplace and determine ways to eliminate or reduce hazards in the workplace.  OSHA's 300A form is required to be posted until April 30, 2018, and must be retained for 5 years.  During the retention period, you are required to update the log to add new information regarding the occupational injuries and illnesses recorded on it.  OSHA has a brief tutorial to help you complete the forms.  
OSHA 300 Log Form
A final rule was issued and went into effect on January 1, 2017, requiring certain employers to electronically submit injury and illness data to OSHA.  OSHA has provided an online secure website (click here for the website) for submitting this information. You must submit this information by March 2, 2019, OSHA will start collecting the information on January 2, 2019.  If you meet the following criteria you DO NOT have to electronically submit your 300A information to OSHA: 

OSHA 300A Form - Posting/Reporting Form

  • The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry. 
  • The establishment's industry is on this list, regardless of the size of establishment.
  • The establishment had peak employment between 20 and 249 employees during the previous calendar year and the establishment's industry is not on this list.  Construction and Remediation and other waste management services are both on this list, so if you are in those industries and meet the size requirements you must electronically report your OSHA 300A information.
  • Establishments under the jurisdiction of these State Plan states do not currently have to electronically submit to OSHA: California, MarylandMinnesotaSouth CarolinaUtahWashington, and Wyoming.

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