Question

This is my first time filling out the OSHA 300A form. Is there anything special to be aware of regarding the form?

Answer

It should be a fairly simple process since all your information on the 300A is based upon what you have been recording all year on the OSHA 300 form. But depending on the size of your company and the industry in which you operate, some exceptions may apply.

As we move toward the end of January, now is the time that every employer subject to the Occupational Safety and Health Act law (OSHA) – generally employers of 10 or more employees – should complete the mandatory OSHA 300A form. Once completed, employers should be ready to post their OSHA Form 300A for 2023 no later than February 1, 2024.

The OSHA forms 300 and 300A, as well as straightforward instructions on how to complete the forms, are available from the OSHA website.

The summary must include the total number of job-related injuries and illnesses that occurred in 2023 and were logged on OSHA Form 300, Log of Work-Related Injuries and Illnesses. To assist in calculating incidence rates, information about the annual average number of employees and total hours worked during the calendar year is also required. If a company recorded no injuries or illnesses in the preceding year, the employer must enter “zero” on the total line. Once completed, the 300A summary form must be signed and certified by a company executive and then posted in a visible location in the workplace between February 1 and April 30, 2024.

Employers with 10 or fewer employees and employers in certain low-hazard industries are normally exempt from federal OSHA injury and illness recordkeeping and posting requirements.

Reportable injuries

All employers covered by OSHA must comply with safety and health standards, and accidents that result in one or more fatalities or in the hospitalization of three or more employees must be reported orally within eight hours to the nearest OSHA office no matter the size of the employer.

Generally, only serious injuries that are the result of workplace activity should be included on the Form 300. A serious injury is one that results in a fatality, loss of consciousness, days away from work, a restricted work schedule or job transfer, or a significant injury or illness diagnosis by a health-care provider, or that requires medical treatment beyond basic first aid. Incidents that only require first aid should not be reported.

If the injury involved is of a sensitive nature, such as sexual assault, employers should write “privacy case” in the box for the worker’s name.

Companies are required to update and maintain records for five years plus the current year and provide them to OSHA investigators for inspection.

However, 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. Massachusetts has three offices where an employer may report a serious injury.

OSHA Reporting and COVID-19

Under mandatory OSHA rules employers are required to record work-related cases of COVID-19 illness on OSHA’s Form 300 logs if the following requirements are met:

· the case is a confirmed case of COVID-19; · the case is work-related (as defined by 29 CFR 1904.5); and · the case involves one or more relevant recording criteria (set forth in 29 CFR 1904.7) (e.g., medical treatment, days away from work). Employers must follow the requirements in 29 CFR part 1904 when reporting COVID-19 fatalities and hospitalizations to OSHA. More information is available on OSHA’s website. Employers should also report outbreaks to local health departments as required and support their contact tracing efforts.

AIM members with questions about this or any other human resources issue may contact the AIM Helpline at 1-800-470-6277.