OSHA Alert: OSHA 300A Summary

Date: Jan 10, 2007

As a friendly reminder, the OSHA 300A Summary form needs to be posted from 1 February until 30 April. The OSHA rule is posted at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12776

In a nutshell, the person responsible for maintaining the daily OSHA 300 Log must:

  1. Review the Log, verify that entries are complete and accurate, correct any deficiencies identified and tally the Log.
    1. Total the columns on the OSHA 300 Log (if you had no recordable cases, enter zeros for each column total); and
    2. Make sure the Log includes the calendar year covered, the company's name, establishment name, establishment address, annual average number of employees covered by the Log, and the total hours worked by all employees covered by the Log.
  2. Prepare an annual summary of the injuries and illnesses recorded on the OSHA 300 Log, using the OSHA 300-A summary form or equivalent. If you are using an equivalent form, as permitted under ยง 1904.6(b)(4), make sure you include the employee access and employer penalty statements found on the OSHA 300A Summary form.
  3. Have the 300A Summary form certified by a company executive.
    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. The company executive can be: 1) an owner of the company (only if the company is a sole proprietorship or partnership); 2) an officer of the corporation; 3) the highest ranking company official working at the establishment; or 4) the immediate supervisor of the highest ranking company official working at the establishment.
  4. Post the 300A Summary.
    Post a copy of the annual summary in each establishment in a conspicuous place or places where notices to employees are customarily posted. Also, you must ensure that the posted summary is not altered, defaced or covered by other material.

If you have any questions or concerns, please contact Stefanie Corbitt at 202-434-4276 or corbitt@khlaw.com.