OSHA 300A Posting Deadline Is February 1 for Non-California Employers

From February 1 through April 30, most employers are required to post the OSHA Form 300A Annual Summary Log of Injuries and Illnesses that occurred in 2019, the previous calendar year.

Exemptions

If your company had 10 or fewer employees at all times during the last calendar year, your company does not need to keep OSHA injury and illness records.

Additionally, employers are not required to keep OSHA injury and illness records for any establishment classified in the following North American Industry Classification System (NAICS), unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye (see §1904.39).

You may view the exemption table by following this link:

https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html

Form 300A is designed to alert workers to hazards that may exist in their workplace.  Even if an employer had no recordable injuries or illnesses in 2019, the previous calendar year, employers must still post a summary with zeros in the total line.

Employers are required to post this summary in a conspicuous place where they normally post notices to employees, such as a break room.  During this posting period, employers are also responsible for making sure employees don’t deface the posting or cover it up with other material.

Employers must also make a copy of the summary available to employees who move from worksite to worksite, such as construction workers, and employees who do not report to any fixed establishment on a regular basis.

Please click on the link below to be redirected to the United States Department of Labor OSHA Injury & Illness Recordkeeping Forms available for download:

https://www.osha.gov/recordkeeping/RKforms.html

Covered employers are required to electronically submit information from the OSHA Form 300A to OSHA by March 2nd of the year after the calendar year covered by the form.  You can provide the Agency your OSHA Form 300A information through the Injury Tracking Application (ITA), which is accessible from the ITA launch page.

Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. According to the Agency, establishments that meet any of the following criteria DO NOT have to send their information. Remember, these criteria apply at the establishment level, not to the firm as a whole.

  • 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 the establishment.
  • The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on this list.

If you have any questions or need further information, please don’t hesitate to contact our office at (661) 631-2165.

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