OSHA 300A Forms - Reminder to Post

Reminder to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses for all US employers, except those with 10 or fewer employees or whose NAICS code is in the set of low-hazard industries exempt from OSHA's injury and illness recordkeeping requirements. This form needs to be posted through April 30th.

Do NOT confuse the OSHA 300A Form with reporting of the electronic data reported to OSHA from the 300A form by March 2, 2020. 
This is your yearly reminder about the important February 1st deadline to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses, for all U.S. employers, except those with ten or fewer employees or those whose NAICS code is in the set of low-hazard industries exempt from OSHA's injury and illness recordkeeping requirements.

Electronic Recordkeeping Rule 
This February 1st requirement to prepare, certify and post 300A forms should not be confused with OSHA's new Electronic Recordkeeping Rule.  The February 1st deadline is only about the internal hard copy posting of 300A data for your employees' eyes.  The E-Recordkeeping Rule, on the other hand, requires certain employers to electronically submit data from their 300A Annual Summary forms to OSHA through OSHA's web portal – the Injury Tracking Application. The deadline for those submissions this year (i.e., to submit 300A data from 2018) is March 2, 2020.

By February 1st every year, however, employers must:
  • Review their OSHA 300 Log(s).
  • Verify the entries on the 300 Log are complete and accurate.
  • Correct any deficiencies identified on the 300 Log.
  • Use the injury data from the 300 Log to calculate an annual summary of injuries and illnesses and complete the 300A Annual Summary Form: and
  • Certify the accuracy of the 300 Log and the 300A Summary Form.
The Form 300A is a summation of the workplace injuries and illnesses recorded on the OSHA 300 Log during the previous calendar year, as well as the total hours worked that year by all employees covered by the OSHA 300 Log.

Five Common 300A Mistakes that Employers Make
  1. Not having a management representative with high enough status within the company “certify” the 300A.
  2. Not posting a 300A for years in which there were no recordable injuries.
  3. Not maintaining a copy of the certified version of the 300A form.
  4. Not updating prior years' 300 Logs based on newly discovered information about previously unrecorded injuries or changes to injuries that were previously recorded: and
  5. Confusing or conflating the requirement to Post a 300A in the workplace with the requirement to electronically submit 300A data to OSHA's web portal.
Certifying the 300 Log and 300A Annual Summary
The 300 Log and the 300A Annual Summary Form are required to be “certified” by a “company executive.”  Specifically, what the company executives are certifying is that they:
  1. Personally examined the 300A Annual Summary Form;
  2. Personally examined the OSHA 300 Log from which the 300A Annual Summary was developed; and
  3. Reasonably believe, based on their knowledge of their companies' recordkeeping processes that the 300A Annual Summary Form is correct and complete.
Common mistake employers make is to have a management representative sign the 300A Form who is not at a senior enough level in the company to constitute a “company executive.”  As set forth in 1904.32(b)(4), company executives include only the following individuals:
  • An owner of the company (only if the company is a sole proprietorship or partnership).
  • An officer of the corporation;
  • The highest-ranking company official working at the establishment; or
  • The immediate supervisor of the highest-ranking company official working at the establishment.
Posting the 300A Annual Summary
After certifying the 300A, OSHA's Recordkeeping regulations require employers to post the certified copy of the 300A Summary Form in the location at the workplace where employee notices are usually posted.  The 300A must remain posted there for three months, through April 30th.

Another common mistake employers make is to not prepare or post a 300A Form in those years during which there were no recordable injuries or illnesses at the establishment.  Even when there have been no recordable injuries, OSHA regulations still require employers to complete the 300A form, entering zeroes into each column total, and to post the 300A just the same.

Maintaining a Copy of the 300A for Five Years
After the certified 300A Annual Summaries have been posted between February 1st and April 30th, employers may take down the 300A Form, but must maintain for five years following the end of the prior calendar year at the facility covered by the form or at a central location, a copy of:
  • The underlying OSHA 300 Log;
  • The certified 300A Annual Summary Form; and
  • Any corresponding 301 Incident Report forms.
In this technology era, many employers have transitioned to using electronic systems to prepare and store injury and illness recordkeeping forms. As a result, another common mistake employers make is to keep only the electronic version of the 300A, and not the version that was printed, “certified,” typically by a handwritten signature, and posted at the facility. Accordingly, those employers have no effective way to demonstrate to OSHA during an inspection or enforcement action that the 300A had been certified.

Updates to OSHA Injury and Illness Recordkeeping Forms 
Another common mistake employers make is to put away old 300 Logs and never look back, even if new information comes to light about injuries recorded on those logs.  However, OSHA's Recordkeeping regulations require employers during the five-year retention period to update OSHA 300 Logs with newly discovered recordable injuries or illnesses, or to correct previously recorded injuries and illnesses to reflect changes that have occurred in the classification or other details.  This requirement applies only to the 300 Logs; i.e., technically there is no duty to update 300A Forms or OSHA 301 Incident Reports.

Submitting Electronically to OSHA
If you are an establishment with more than 20 employees covered under the OSHA recordkeeping requirements, you need to submit your OSHA 300A information electronically to OSHA using their injury tracking application (ITA).  Establishments currently have until March 2, 2020 to submit their 300A information to OSHA for the previous year. While OSHA's electronic submissions are under potential revision (See below) the 300A electronic submission appears here to stay.

For more detailed guidance on how to use the Injury Tracking Application see

Information provided by Marc McClure
OSC Safety Inc.| M: (308) 991-8794 | E:


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