Don’t Forget: Post OSHA Form 300A on February 1

If you are an employer who is required to maintain work-related injury and illness records, you must post OSHA Form 300A (summary of the OSHA log of injuries and illnesses) in a conspicuous place on February 1 and keep it up until April 30. Refer to this chart to see if you are exempt from this requirement.

Submitting Form 300A electronically

Some employers are required to submit the injury and illness summary data to OSHA electronically. The deadline for submitting this information is March 2. The following information found on the OSHA website will help you determine if you are required to report your information electronically:

Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to send their information to us. 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.

Additional information on electronic submission

The following information was recently posted by OSHA. Links provided take you to relevant sections of “Tracking of Workplace Injuries and Illnesses” posted in the Federal Register.

Protecting worker privacy

To protect worker privacy, the Occupational Safety and Health Administration (OSHA) is amending the recordkeeping regulation by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 and 301. These establishments will continue to be required to maintain those records on-site, and OSHA will continue to obtain them as needed through inspections and enforcement actions. In addition to reporting required after severe injuries, establishments will continue to submit information from their Form 300A. Such submissions provide OSHA with ample data that it will continue seeking to fully utilize.

Employer EINs

OSHA will require employers electronically submitting Form 301A to submit their EIN.

In addition, OSHA is amending the recordkeeping regulation to require covered employers to submit their Employer Identification Number (EIN) electronically along with their injury and illness data submission, which will facilitate use of the data and may help reduce duplicative employer reporting. Nothing in the final rule revokes an employer’s duty to maintain OSHA Forms 300 and 301 for OSHA inspection.

Compliance date

The requirement to include the EIN for each establishment submitting injury and illness data under 29 CFR 1904.41 will become effective on February 25, 2019. The compliance date for this provision is March 2, 2020. The EIN will therefore be required for covered establishments submitting their 300A data from 2019, but not for covered establishments submitting their 300A data from 2018, which have to be submitted by March 2, 2019.

The Final rule

Complete information, OSHA’s “Tracking of Workplace Injuries and Illnesses,” released January 25, can be found on the Federal Register website.

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Mary van Balen
Mary van Balen
Technical Writer at Delphia Consulting
Mary van Balen is based out of Columbus, Ohio and is a writer for Delphia Consulting. Mary contributes to the Delphia blog on Human Resources issues and Delphia Consulting and Sage product related updates.