Posting the OSHA 300A Annual Summary: What to Do and When

If you keep an OSHA 300 Log, your recordkeeping work is not finished when the last case of the year is entered. The rule gives you four jobs at the end of each calendar year, and one of them comes with fixed dates. Here is what you must do with the log, who has to certify the summary, and exactly when the 300A summary must be posted.

The rule gives you four jobs at the end of each year

At the end of each calendar year, you must (1904.32(a)):

Review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any deficiencies identified (1904.32(a)(1)).
Create an annual summary of injuries and illnesses recorded on the OSHA 300 Log (1904.32(a)(2)).
Certify the summary (1904.32(a)(3)).
Post the annual summary (1904.32(a)(4)).

How deep must the review go? You must review the entries "as extensively as necessary to make sure that they are complete and correct" (1904.32(b)(1)). That sets a result, not a procedure: the paragraph names no sample size and no checklist.

How do you complete the summary?

You must do two things (1904.32(b)(2)):

Total the columns on the OSHA 300 Log. If you had no recordable cases, enter zeros for each column total (1904.32(b)(2)(i)).
Enter the calendar year covered, the company's name, establishment name, establishment address, annual average number of employees covered by the OSHA 300 Log, and the total hours worked by all employees covered by the OSHA 300 Log (1904.32(b)(2)(ii)).

So a year with no recordable cases still gets a summary, with zeros in the totals.

If you use an equivalent form instead of the OSHA 300-A summary form, the summary you use must also include the employee access and employer penalty statements found on the OSHA 300-A Summary form (1904.32(b)(2)(iii)).

Who has to certify it?

A company executive must certify that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete (1904.32(b)(3)).

Note that the executive certifies having examined the log itself, not only the summary.

The company executive who certifies must be one of the following persons (1904.32(b)(4)):

An owner of the company (only if the company is a sole proprietorship or partnership) (1904.32(b)(4)(i))
An officer of the corporation (1904.32(b)(4)(ii))
The highest ranking company official working at the establishment (1904.32(b)(4)(iii))
The immediate supervisor of the highest ranking company official working at the establishment (1904.32(b)(4)(iv))

The person who prepares the summary can certify it only if he or she is also one of those four.

Where and when must it be posted?

You must post a copy of the annual summary in each establishment, in a conspicuous place or places where notices to employees are customarily posted (1904.32(b)(5)). You must also ensure that the posted summary is not altered, defaced or covered by other material (1904.32(b)(5)).

You must post the summary no later than February 1 of the year following the year covered by the records, and keep the posting in place until April 30 (1904.32(b)(6)).

Posting the summary in the workplace is a separate duty from electronically submitting information from these records to OSHA, which is covered by a different section (1904.41).

How long do you keep the records afterward?

You must save the OSHA 300 Log, the privacy case list (if one exists), the annual summary, and the OSHA 301 Incident Report forms for five (5) years following the end of the calendar year that these records cover (1904.33(a)).

During the storage period, you must update your stored OSHA 300 Logs to include newly discovered recordable injuries or illnesses and to show any changes in the classification of previously recorded cases (1904.33(b)(1)).

Which employers do not have to keep the log at all?

There are two partial exemptions, each with conditions.

Size. If your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics informs you in writing that you must keep records under 1904.41 or 1904.42 (1904.1(a)(1)). The count is based on the number of employees in the entire company (1904.1(b)(1)), using your company's peak employment during the last calendar year (1904.1(b)(2)).
Industry. If your business establishment is classified in a specific industry group listed in appendix A to Subpart B of Part 1904, you do not need to keep the records unless the government asks you to keep them under 1904.41 or 1904.42 (1904.2(a)(1)). This exemption applies to individual business establishments, so some of a company's establishments may be required to keep records while others are partially exempt (1904.2(b)(1)).

Neither exemption removes the duty to report to OSHA a work-related fatality, in-patient hospitalization, amputation, or loss of an eye (1904.1(a)(1), 1904.2(a)(1)).

A year-end checklist

Confirm whether you must keep the log (1904.1(a), 1904.2(a)).
Review the log and correct any deficiencies (1904.32(a)(1)).
Total the columns, entering zeros if there were no cases (1904.32(b)(2)(i)).
Have a company executive certify the summary (1904.32(b)(3)).
Post it in each establishment no later than February 1 and keep it in place until April 30 (1904.32(b)(5), 1904.32(b)(6)).
Save the records for five years following the end of the calendar year they cover (1904.33(a)).

Source

This article relies on regulation text in 29 CFR Part 1904 as published by OSHA: 1904.32 (annual summary), 1904.33 (retention and updating), 1904.1 (size exemption), 1904.2 (industry exemption), and 1904.41, named only to point to the separate electronic submission rule. The regulation itself always controls. States that run their own OSHA-approved State Plans may have additional or stricter rules.