Post 2021 Injury-Illness Summary by Feb 1st
Beginning February 1, employers must post a summary of the total number of job-related injuries and illnesses that occurred last year. Minor injuries that are treated only by first aid do not need to be recorded. Employers are only required to post the Summary (OSHA Form 300A) -- not the OSHA 300 Log -- from Feb.1 to Apr. 30, 2022.
Employers must complete the OSHA 300A summary form, even if no work-related injuries or illnesses occurred during the year. However, most employers with 10 or fewer employees, as well as many businesses in certain industry classifications, are exempt from keeping OSHA injury and illness records. For business exemption details review https://www.osha.gov/recordkeeping. However, the Bureau of Labor Statistics may still select exempted employers to participate in an annual statistical survey (employers would receive a notification in the mail).
Prior to posting, a company executive must review and certify (sign) the Summary indicating that the information is true and accurate. The Summary must be posted in a conspicuous place or places where notices to employees are customarily posted.
Electronic Reporting
March 2, 2022, is the deadline for electronically reporting your OSHA 300A data for calendar year 2021, using the Injury Tracking Application on OSHA’s website. Electronic submissions of OSHA 300A Annual Summary are required by establishments with 250 or more employees currently required to keep OSHA injury and illness records, and establishments with 20-249 employees classified in specific industries with historically high rates of occupational injuries and illnesses.
COVID-19 Cases
Under OSHA’s recordkeeping requirements, coronavirus is a potentially recordable illness, and employers must report a case via the OSHA 300 Log when a COVID-19 case is work-related and the case meets recording criteria in 29 CFR 1904.7:
The case is a confirmed case of COVID-19, meaning that the individual had at least one sample test positive for SARS-CoV-2, the virus that causes COVID-19;
The case is work-related, meaning that an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness; and
The case results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or in-patient hospitalization.
This means that COVID-19 differs from the flu; there is no obligation to record flu cases, even if it spreads through the workplace. In other words, employers won’t record every COVID-19 case that appears in the workplace. But each case must be investigated for work-relatedness and then record it on the OSHA 300 Log when evidence of work-relatedness appears. OSHA will judge employers based on the reasonableness of their investigation and the evidence available to them. And because most confirmed COVID-19 cases will result in days away from work, the vast majority of work-related cases should be on the OSHA 300 Log.
OSHA can cite an employer who fails to post the OSHA 300A Summary as required. Employers should take steps now to ensure they are fully compliant.
If you need assistance preparing your OSHA 300A Summary or have another OSHA compliance issue, please contact us today.