It’s that time of year to look back on your workplace illnesses and injuries for 2014, ensure that you have recorded the correct information in your OSHA logs, and post the information in your workplace starting February 1, 2015. Do you need to comply with this posting requirement, even if you’ve had no injuries or illnesses this past year? You probably will need to comply — most employers do.
Employers are responsible for providing a safe and healthful workplace for their employees. The role of the Occupational Safety and Health Administration (OSHA) is to assure the safety and health of workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health. Employers are required to have a Workplace Injury and Illness Prevention Program in place, with active monitoring of results. The intent of the OSHA log reporting is to summarize the year end results and focus both employers’ and employees’ attention on workplace safety so that everyone can make safety a top company priority.
Do you need to comply with the February 1st deadline?
If you had 10 or more employees at all times during 2014, you will need to comply, unless your company’s Standard Industrial Classification (SIC) Code is included in the industry list of exclusions available at https://www.osha.gov/oshstats/naics-manual.html.
What You Should Do
Assuming that your business does not fall under the exclusions of OSHA reporting, you’ll need to ensure that two OSHA forms are completed fully, the Form 300 (log) and the Form 300A. Both forms and the instructions can be accessed here.
Form 300: This form is used to record all injuries and illnesses, except those that required first aid only. This form is not posted due to privacy considerations. There are certain injuries and illnesses where you do not include the employee’s name for privacy (sexual assaults, HIV infection, etc.), and an employee may request that his or her name not be entered on this log.
Form 301 (do NOT post): This form allows you to record more data about how the injury or illness occurred. As with Form 300, this form is not posted due to privacy considerations. Employee representatives, however, may have access to this form but only the portion that contains no personal information.
Form 300A: This is the form that must be completed and posted beginning February 1st through April 30th. It contains a summary of the total number of job-related injuries and illnesses that occurred during the previous year that were logged onto the Form 300. Information about the annual average number of employees and total hours worked during the calendar year is required for calculating incidence rates. Companies with no recordable injuries or illnesses in the previous year must post the summary with zeros on the “total” line. A company executive must certify all establishment summaries. Employers are required only to post the summary Form 300A, not the Form 300 log.
Form 300A must be displayed in a common area where notices to employees usually are posted. Employers must 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 one office on a regular basis.
More information regarding OSHA’s recordkeeping rule can be found in the OSHA Fact Sheet.