Deadlines Approaching - OSHA Posting and Filing Requirements

Every year most employers are required to post their OSHA Form 300A - Summary of Work-Related Injuries and Illnesses (a.k.a., OSHA Recordable Cases). The Form 300A is to be posted in each establishment where notices are normally posted no later than February 1st of the year following the year covered by the records. It must remain posted until April 30th.

If your company always has 10 or fewer employees during the year, you are partially exempt from the routine recordkeeping requirements from OSHA. This exemption applies at the company level, meaning if you have more than one location, you must include the employees from all your locations in your count. When counting how many employees each establishment had for 2022, employers must be careful to count each individual employed at the establishment at any time during the calendar year, including part-time, seasonal, and temporary workers. Employers who are partially exempt from keeping injury and illness records only have to submit their Form OSHA 300A if OSHA directs them to do so.

As a reminder below is a list of what OSHA considers to be a Recordable Case injury or illness to be included on the Form 300A:

• Any work-related fatality.
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
• Any work-related injury or illness requiring medical treatment beyond first aid.
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis

In addition, establishments with 250 or more employees, and establishments with 20-249 employees that are classified in certain high-hazard industries, must also submit their Form 300A data electronically to OSHA by March 2nd for the prior year. This submission is completed through OSHA’s Injury Tracking Application system.

These recordkeeping requirements and deadlines are separate from the OSHA reporting requirements for work-related fatalities, hospitalizations, amputations and losses of an eye. Even employers who are exempt from routinely keeping OSHA injury and illness records (due to company size or industry) are still required to report these severe injuries or fatalities. Employers must report work-related fatalities within 8 hours of finding out about them or of learning they were work-related. For any inpatient hospitalization, amputation, or eye loss, employers must report it within 24 hours of learning about it.