OSHA Posting Requirements: Injuries or Illness

The Occupational Safety and Health Administration (OSHA) requires employers to post the summary form for injuries that occurred during the previous year from February 1-April 30.

Employers are only required to post OSHA Form 300A (summary), not the OSHA 300 log. March 2, 2021 is the deadline to electronically report your OSHA Form 300A data for calendar year 2020. Employers with ten (10) or fewer employees and employers in certain industry groups are normally exempt from federal OSHA injury and illness recordkeeping and posting requirements.

The ITA website (Injury Tracking Application) should be used to electronically submit required injury and illness data. The website also has instructions for completing the Form 300A.

The summary must list the total number of job-related injuries and illnesses that occurred in 2020 and were logged on the OSHA 300 form. Under OSHA's recordkeeping requirements, COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19 if:

• [1] the case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);
• [2] The case is work-related as defined by 29 CFR § 1904.5;
• [3] and the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7.
• [4] Information about the annual average number of employees and total hours worked during the calendar year is also required to assist in calculating incidence rates.

Companies with no recordable injuries or illnesses in 2020 must post the form with zeroes on the total line. All summaries must be certified by a company executive. Please note, no employee names or other identifying information is to be placed on the OSHA Form 300A.

The form is to be displayed in a common area wherever notices to employees are usually posted. While there is no change to the requirement of where the log should be posted, in light of many employees currently working remote, it is suggested that employers also make the log available via an online protected format, such as an intranet. A copy of the summary must be made available to employees who move from worksite to worksite, such as construction employees and employees who do not report to any fixed establishment on a regular basis.

Exempted employers may still be selected by the Department of Labor's Bureau of Labor Statistics to participate in an annual statistical survey.

Action Steps:

• Review industry exemptions to determine if exempt.
• Post OSHA Form 300A (summary) if required.

Stay on top of the changing compliance requirements as a result of the pandemic. Download the COVID-19 and Employee Benefits Toolkit to access the latest benefits changes, laws and regulations impacting your business