It’s that time of year again. OSHA requires covered employers to post their OSHA Form 300A from February 1 through April 30 each year.
Form 300A summarizes job-related injuries and illnesses during 2017. Employers should post the form in a common area (i.e. break room, cafeteria) where notices to employees are usually found.
Employers with 10 or fewer employees and those in specific low-hazard industries are exempt from federal OSHA injury and illness recordkeeping, including the Form 300A requirement.
No injuries in 2016? You still have to post Form 300A and fill it out to reflect that you didn’t have any injuries.
You will also have to record the annual average number of employees and the total hours worked by all employees last year. OSHA has a worksheet if you need help calculating those numbers. The recent rulemaking, which requires certain employers to electronically submit the injury and illness information in July, 2017, does not impact or change the posting of their OSHA Form 300A.
Not sure how to count temporary employee hours. Injuries and illnesses should be recorded on only one employer’s injury and illness log (29 CFR1904.31 (b)(4)). In most cases, the host employer is the one responsible for recording the injuries and illnesses of temporary workers.
Injury and illness recordkeeping responsibility is determined by supervision. Employers must record the injuries and illnesses of temporary workers if they supervise such workers on a day-to-day basis (29 CFR 1904.31(a)). Day to-day supervision occurs when “in addition to specifying the output, product, or result to be accomplished by the person’s work, the employer supervises the details, means, methods, and processes by which the work is to be accomplished.” See OSHA FAQ 31-1. (Essentially, an employer is performing day-to-day supervision when that employer controls conditions presenting potential hazards and directs the worker’s activities around, and exposure to, those hazards.) In most cases, the host employer provides this supervision.
Contact Terry Cirone with any questions.