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Federal Law Alert: OSHA Form 300A Must be Posted by February 1

Jan 25, 2022 | Compliance and Labor Laws

From the pros at the HR Support Center
Employers that had 11 or more employees at any point in 2021 are required to post Occupational Safety and Health Administration (OSHA) Form 300A from February 1 through April 30 unless they qualify as an exempt low-risk industry. A full list of exempt low-risk industries, ordered by North American Industry Classification System (NAICS) codes, can be found here.

The employee count is based on the number of employees in the entire company, not per establishment. If the company is subject to routine recordkeeping requirements, records must be maintained for each physical establishment.

All covered employers are required to post Form 300A even if they didn’t have any recordable incidents in 2021. (Recordable incidents are required to be maintained on the OSHA 300 Log of Work-Related Injuries and Illnesses.) OSHA Form 300A must be certified by a company executive and posted in a conspicuous location where notices to employees are customarily posted.

The OSHA Log of Work-Related Injuries and Illnesses (Form 300), Summary (Form 300A), and Instructions can be downloaded from OSHA directly here.

If your workplace is currently closed because of COVID-19, and you are unable to post the log there, we recommend posting it on your company intranet page, virtual bulletin board, or other location online where it can be easily seen and accessed by employees. If you return to the workplace before April 30, you should also physically post it at that time.

Form 300A Electronic Submission Required for Certain Employers by March 2
Employers must submit their 2021 Form 300A data to OSHA if they have 250 or more employees or have 20–249 employees and are in certain high-risk industries. Employers must use OSHA’s online Injury Tracking Application (ITA). The deadline to submit the report is March 2, 2022.

The electronic reporting requirements are based on the size of the establishment (how many employees are at the physical location), not how many employees are in the entire company.

Employers that are required to send their Form 300A to OSHA must submit injury and illness data using the ITA online portal. This also applies to employers that are covered by a State Plan that has not yet adopted its own state rule.

Employers that meet any of the following criteria DO NOT have to send their information to OSHA:

  • Employers that are exempt from OSHA’s routine recordkeeping requirements, as mentioned above.
  • Employers that never had 20 or more employees during the previous calendar year, regardless of industry.
  • Employers that had between 20 and 249 employees at some point during the previous calendar year but are NOT on this list of high-risk industries.

Additional information, FAQs, and the Injury Tracking Application can be found on OSHA’s site, here.

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