Preparing for OSHA’s Recordkeeping Deadline: Common Questions and Mistakes

OSHA’s Recordkeeping deadline is quickly approaching. By February 1, employers in the U.S. covered by the rule are required to prepare, certify and post a signed hard copy of their Summary of Work-Related Injuries and Illnesses (Form 300A) in a location accessible to employees to view.

While OSHA has made no changes to the Rule requirements this year, many employers continue to make common recordkeeping mistakes, some of which potentially affect compliance and can lead to steep fines. One of these mistakes is not to post the form at all. Employers obligated to submit information to OSHA through the Agency’s Injury Tracking Application (ITA) are also still obligated to post their Form 300A in their facility for onsite employees to see.

Who is Covered by the Recordkeeping Rule?

OSHA’s Recordkeeping Rule covers all employers with 11 or more employees in the company at any time during the calendar year, unless their NAIC code is included on the Partially Exempt List. All employers covered by the rule are required to keep occupational injury and illness records including the Log of Work-Related Injuries and Illnesses (Form 300), individual Injury and Illness Incident Reports (Form 301s) for each recordable injury or illness, and the Form 300A.

While employers with ten or fewer employees in the company or those who are in one of the low hazard industries listed on the partially exempt list are not required to maintain these forms, they are still required to report any fatalities (within eight hours), hospitalizations of one or more employees (within 24 hours) and incidents involving amputation or loss of eye (within 24 hours).

Do I Have to Post Form 300A, And How Long Must It Stay Up?

If your establishment is part of a company that is covered by the recordkeeping rule, you must complete and post a signed hard copy of form 300A summarizing your facility’s 2019 occupational injury and illness data by February 1 of each year. The form must be posted in a location that is clearly visible to employees and new applicants, and must remain up until April 30, after which it can be taken down.

Who Must Sign the Form?

OSHA requires a “company executive” to sign Form 300A prior to it being posted. This expresses OSHA’s intent that the signer should be an individual with a high degree of responsibility and authority for the facility. Since the signature certifies that the information in the document is “true, accurate, and complete,” OSHA considers this a crucial step, and views unsigned forms as being out of compliance.

Do I Have to Post Form 300A Even If There Were No Recordable Injuries?

All covered employers must fill out and post the summary annually, even if no recordable work-related injuries or illnesses occurred during the reporting year.

Should I Also Post Previous Years’ Forms Alongside Form 300A from 2019?

No. Before posting Form 300A from 2019 you should ensure that any old or outdated forms have been taken down. Keeping forms from other years outside of 2019 can confuse employees, and OSHA can potentially judge a facility with outdated or conflicting forms posted to be out of compliance.

When Do I Still Need to Submit Form 300A to OSHA?

The Recordkeeping Rule has undergone a number of updates in the last few years, especially those concerning OSHA’s Electronic Reporting Rule. While the deadline for posting the physical Form 300A has not changed, under the Agency’s new electronic recordkeeping rule, some establishments must also now submit data from Form 300A using the agency’s Injury Tracking Application – or ITA – by March 2. More details about this requirement can be found here.

Still have questions about OSHA’s Recordkeeping Rule? Our EHS QuickTake video provides a helpful summary of the rule and its requirements.

Let VelocityEHS Help!

Our easy-to-use, Incident Management solution helps streamline the reporting process by enabling you to generate the injury and illness summaries you are required to post on-site each February, as well as quickly complete the necessary forms to meet the electronic submission requirements via OSHA’s ITA. Together with the award-winning VelocityEHS Mobile App, you’re able to better manage workplace incidents by engaging your front-line workers to instantly report accidents, near misses and hazards as they occur – with or without internet connectivity – via a smartphone or tablet device for faster, more detailed and accurate accounts of reportable incidents.

Our library of complementary educational resources includes the OSHA Recordkeeping Infographic, which helps EHS professionals quickly and easily determine which workplace incidents are OSHA recordable or reportable, what next steps need to be taken and when, and live webinar, “OSHA's Recordkeeping Standard: Your Guide to Compliance.” Held on February 18 and March 5 from 11 a.m. to 12 p.m. ET, the in-depth webinar offers a comprehensive review of the most recent updates to the Recordkeeping Standard and current Electronic Reporting applicability and due dates, along with best practices for ensuring compliance from our EHS experts.