RISK INSIGHT: OSHA Form 300A Reporting Reminder

Property & Casualty, Risk

Reminder to post your OSHA Form 300A Log Summary by February 1, 2019

It’s that time of year again. February 1st marks the deadline for industries required to maintain an OSHA 300 Log to tabulate their annual OSHA Log Summary (OSHA Form 300A) and post it in a common area (i.e. wherever notices to employees are usually posted).

The OSHA Log Summary – which is required to stay posted until April 30, 2019 – must list the total number of job-related injuries and illnesses that were logged in the calendar year of 2018.  If you are unsure if you are required to maintain an OSHA Log, review the list of industries exempt for OSHA recordkeeping.

Now Open: Electronic Submission of 2018 OSHA Form 300A Data

Employers can now (as of January 2, 2019) begin to electronically report their Calendar Year (CY) 2018 Form 300A data to OSHA through the agency’s Injury Tracking Application (ITA) website. All covered establishments must submit the information by March 2, 2019 (CY 2017 data was required to be submitted by July 1, 2018).  While employers can view their submitted CY 2017 Form 300A summary information, they cannot edit or submit additional 2017 data on the ITA website.

If your establishment meets any one of the following criteria, you DO NOT have to send Form 300A data to OSHA. Remember, this criteria applies at the establishment level, not to the firm as a whole.

  • Peak employee count during the previous calendar year was 19 or fewer, regardless of the establishment’s industry
  • Industry is on the partially exempt list, regardless of the size of the establishment
  • Peak employee count of between 20 and 249 during the previous calendar year AND the establishment’s industry is not on this list

Covered establishments with 250 or more employees are only required to provide their 2018 Form 300A summary data. OSHA is not accepting Form 300 and 301 information at this time. OSHA issued a notice of proposed rulemaking (NPRM) on July 30, 2018 to rescind the requirement of submittal of Form 300/301 data in the “Improve Tracking of Workplace Injuries and Illnesses” final rule; comments are closed as of September 28, 2018.

If you need additional assistance, have questions about OSHA recordkeeping please feel free to contact your M3 Account Executive or Risk Manager for more information.

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