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Federal Law Alert

Reminder: OSHA 300A Forms Must Be Posted by February 1
The Occupational Safety and Health Administration (OSHA) mandates that all employers who are required to maintain the OSHA 300 Log of Work-Related Injuries and Illnesses post a summary of the previous year’s log between February 1st and April 30th each year, even if no incidents occurred in the preceding calendar year. The summary (OSHA Form 300A) must be certified by a company executive and posted in a conspicuous location where notices to employees are customarily posted. 

All employers who had more than ten employees at any point during the last calendar year are covered by this requirement unless they qualify as part of an exempt low-risk industry.

The OSHA Log of Work-Related Injuries and Illnesses (Form 300), Summary (Form 300A) and Instructions can be found in the Forms section of the HR Support Center by searching for “OSHA Form 300.” It’s called “OSHA Form 300, 300A, 301, and Instructions.”

Electronic submission requirements: 
OSHA-covered employers with 250 or more employees, and those in certain high-risk industries with 20-249 employees, must electronically report their Calendar Year 2018 Form 300A data by March 2, 2019. Reporting must be done through the online Injury Tracking Application (ITA). 

All affected employers must submit injury and illness data in the ITA online portal, even if the employer is covered by a State Plan that has not completed adoption of their own state rule. 

Additional information, covered-employer criteria, FAQs, and the Injury Tracking Application can be found on OSHA’s site, here

New Final Rule Regarding Electronic Submission of Form 300 and Form 301
Yesterday, OSHA published a Final Rule to amend its recordkeeping regulations to remove the requirement to electronically submit information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. These requirements were never enforced, but are now officially off the books. These employers are still required to submit Form 300A information electronically, as described above.

Content provided by TPC HR Support Center.