As the OSHA Posting Deadline Nears, Are You Ready?
January 30, 2012
By: Catherine P. Wells, Margaret O'Rourke Wood, and Denise J. Pipersburgh
Wolff & Samson Employment Law Alert
By February 1, 2012, employers subject to the recordkeeping requirements of the Occupational Safety and Health Administration (OSHA) must be ready to post Form 300A, “Summary of Work-Related Injuries and Illnesses.” OSHA requires that the Form be posted at each worksite by the employer, unless the company has 10 or fewer employees or falls within one of the industries normally exempted from the Occupational Safety and Health Act’s recordkeeping and posting requirements.
Form 300A is the official summary of all workplace illnesses and injuries occurring over the previous calendar year. In completing the annual summary, the employer must review and verify that the OSHA Form 300 (the log of injuries and illnesses) for each worksite is accurate and complete: any deficiencies in the log must be corrected so that the establishment’s records are accurate.
Once Form 300A has been prepared, a company executive must certify this annual summary. In accordance with OSHA’s requirements, the executive must certify that “he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.” A company executive may be either: (i) an owner of the company (if a sole proprietorship or partnership); (ii) an officer of the corporation; (iii) the highest ranking company official working at the establishment; or (iv) the immediate supervisor of the highest ranking company official working at the worksite.
Form 300A must be posted conspicuously in the workplace where notices to employees are customarily posted. The Form must remain posted until April 30, 2012.
The OSHA forms, and instructions for completing these forms, may be found on OSHA’s website online at: http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf.
For more information, please contact:
Catherine P. Wells, Member of the Firm
(973) 530-2051 / cwells@wolffsamson.com
Margaret O’Rourke Wood, Member of the Firm
(973) 530-2063 / mwood@wolffsamson.com
Denise J. Pipersburgh, Associate
(973) 530-2090 / dpipersburgh@wolffsamson.com
