February 1: OSHA Form 300A Posting

Annually, the Occupational Safety and Health Administration (OSHA) requires qualifying employers to post their OSHA Form 300A copies between February 1 and April 30. The OSHA Form 300A, also known as the “Summary of Work-Related Injuries and Illnesses,” must be completed by February 1. Each year’s filing must utilize data from the previous calendar year. Employers with 10 or fewer employees or identified within an exempt industry are excluded from the OSHA recordkeeping requirement.

Severe Injury Reporting

All worker fatalities must be reported to OSHA by employers within eight hours. Employee amputations, loss of an eye, or hospitalization is required to be reported within 24 hours of the incident. Organizations should default to the emergency temporary standard for all COVID-19-related illnesses as it provides the reporting timeframes for when to report a death or inpatient hospitalization.

Employer Action Steps

Employers subject to OSHA recordkeeping requirements must ensure on February 1 that completed 300A Form copies are posted in each of their establishments. The form must be displayed in a conspicuous place or location where employee notices are customarily posted. The Form 300A postings must remain in place until April 30. Employers must be diligent to ensure the postings are not altered, defaced or covered with other materials.

March 2: OSHA Electronic Reports Due

Each year, OSHA requires certain employers to submit information from their OSHA Form 300A electronically using its Injury Tracking Application (ITA).

Affected employers include:

• Establishments with 250 or more employees, if they are already required to create and maintain OSHA records; and
• Establishments with between 20 and 249 employees that are in a high-risk industry.

Otherwise exempt establishments may be required by OSHA or the Bureau of Labor Statistics, on a case-by-case basis, to submit these reports. Under the OSHA emphasis program, the organization collects injury and illness information to identify emerging hazards, characterize specific areas of concern, or target inspection and outreach initiatives.

Submission Expansion Rule

Starting January 1, 2024, OSHA mandates certain employers in identified high-hazard industries to electronically submit their required injury and illness records. Submission requirements include:

• Establishments with 100 or more employees in certain high-hazard industries must electronically submit their Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report to OSHA once a year. These requirements are in addition to the submission of Form 300A-Summary of Work-Related Injuries and Illnesses.
• To improve data quality, establishments are required to include their legal company name when making electronic submissions to OSHA from their injury and illness records.

The OSHA electronic reporting coverage rule is only based on establishments. While an employer may have several worksites or establishments, some locations will be affected while others are not.

Employers can determine if their establishment is affected by evaluating each location’s peak calendar year employment. Every full-time, part-time and temporary or seasonal individual who worked at that establishment must be counted. Any organization with multiple locations may submit establishment-specific data.

We’re Here to Help Keep Your Business Compliant

Navigating through OSHA-specific reporting can be confusing. The insurance professionals at CBIZ are not only able to provide you protection for all of the risks your business may encounter, but we believe risk mitigation strategies can help prevent exposures. Connect with a member of our team to learn more about the coverages and advantages our clients receive.

This content is not intended to be exhaustive, nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.