New Requirements for OSHA’s 300A Summary

This is a friendly reminder about posting your OSHA 300A Summary by February 1st. If you have not posted it yet, now is a good time to complete this easy task.  The other part of this annual posting notification is to go over new rules for the electronic submission of the 300A. Employers must post the completed form in a location where all employees can see it. Examples include places like break rooms, public bulletin boards, and conference rooms. The paper copy must be posted from February 1st to April 30th.

The February 1st requirement to prepare, certify and post 300A forms should not be confused with  OSHA’s new-ish Electronic Recordkeeping Rule.  The February 1st deadline only applies to the hard copy posting of  the 300A.  The E-Recordkeeping Rule, on the other hand, requires certain employers to electronically submit data from their 300A  Annual Summary forms to OSHA through OSHA’s web portal – the Injury Tracking Application. The deadline for those submissions this year is March 2, 2019.
The good news is, only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to submit their information to OSHA. Remember, these criteria apply at the establishment level, not to the firm as a whole.
· If your company’s peak employment during the previous calendar year was 19 or fewer,  regardless of the establishment’s industry you DO NOT need to submit.
· If your company’s industry is on this exempt list, regardless of the size of the establishment, you DO NOT need to submit.
· If your company had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on this list, then you DO NOT need to submit.
If you are on the list, and have 20-249 employees, you must submit your 300A using the Injury Tracking Application (ITA) website.
Again, the OSHA 300A form for 2018 must be electronically submitted by March 2nd 2019. Unless more changes are made to the rule, this deadline will be the same every year moving forward.
So how do employers submit this data? If you do fall under the  reporting category, you will need to create an account on OSHA’s Injury Tracking Application (ITA).  Once there, you will to click on the Launch ITA button in the upper right hand corner. This will launch a new window and allow you create your account to submit your 300A Summary. There is a step-by-step guide and a “How To” that will walk you through the process.
 Should you have any questions concerning, your OSHA 300 and 300A Summary log please contact your LL Roberts Group PEO Risk Management Department (toll free) at 877.878.6463. You can even talk to us on Facebook or Twitter!

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