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What is OSHA Form 300A Summary?

What is OSHA Form 300A Summary?

The Occupational Safety and Health Administration’s COVID vaccine mandate—which the Supreme Court recently blocked—has been controversial to say the least. For some time, however, there’s been a much broader consensus about OSHA’s authority to protect employees from work-related injuries and illnesses. 

In order to comply with OSHA's recordkeeping requirements, certain employers must complete, post, and submit OSHA Form 300A. Here’s what you need to know.

 

What is OSHA Form 300A?

OSHA Form 300A is a summary of injuries and illnesses from the previous year that are “work-related” and “recordable.” This means not all injuries and illnesses experienced in the workplace are considered “work-related”—a matter of context—or rise to the level of “recordable”—a matter of degree. We’ll come back to how OSHA defines those terms in a moment.

OSHA Reporting is a three-step process:

  1. If an incident of injury or illness meets the criteria of “work-related” and “recordable,” the employer must fill out a Form 301 Report. 
  2. Then, the incident must be recorded in the employer’s Form 300 Log for that worksite. 
  3. Finally, after the year’s end, the employer must use the Log to complete their Form 300A Summary.

To comply, the Form 300A Summary—not the Log—must be posted in a highly visible area of each worksite from February 1 through April 30. Employers must also submit the Summary to OSHA by March 2, using their online Injury Tracking Application.

Since January 15, 2022, OSHA’s maximum penalty for noncompliance has been $14,502 per violation for serious, other-than-serious, and posting requirement violations. The maximum penalty for willful or repeated violations is $145,027 per violation.

 

Who is Required to Fill Out OSHA Form 300A?

These reporting requirements apply to employers with more than 10 employees in nonexempt, hazardous industries, such as agriculture, construction, and manufacturing. 

Other employers and industries are referred to as “partially exempt” because there are still particular circumstances in which they must comply:

  1. OSHA requires certain incidents—fatalities, hospitalization, dismemberment—to be reported, regardless of employer status
  2. OSHA or the Bureau of Labor Statistics can require—upon written notice—individual employers who are otherwise exempt to complete Form 300A.

Partially exempt industries include retail, finance, and other low-hazard work environments. For a complete list of partially exempt industries by NAICS code, check out OSHA’s website. You can also look up your industry’s NAICS code on the US Census website.

Non-exempt employers should also note that they must complete and submit Form 300A Summary even if they have no injuries to report.

 

When is an Injury or Illness Considered “Work-Related” and “Recordable”?

According to OSHA, an injury or illness is “work-related” if:

an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace, unless an exception specifically applies.

Just because an employee experiences pain from an injury or symptoms from an illness in the workplace does not necessarily make it “work-related.”

According to OSHA, “recordable” work-related injuries and illnesses are those that result in:

  • death,
  • loss of consciousness,
  • days away from work,
  • restricted work activity or job transfer, or
  • medical treatment beyond first aid.

Additionally, the following work-related incidents should be recorded:

  • any needlestick injury or cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material,
  • any case requiring an employee to be medically removed under the requirements of an OSHA health standard,
  • tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional after exposure to a known case of active tuberculosis, or
  • an employee's hearing test reveals:

that the employee has experienced a Standard Threshold Shift (STS) in hearing in one or both ears, averaged at 2000, 3000, and 4000 Hz 

AND

the employee's total hearing level is 25 decibels (dB) or more above audiometric zero (also averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS.

If employers need help deciding if a case is “work-related” or “recordable,” OSHA encourages you to contact your regional office—or state office if you operate in a “State Plan” state.

 

Additional Resources

For a step-by-step guide to filling out OSHA Forms 300, 300A, and 301, check out this article.

You can stay informed, educated, and up-to-date with HR compliance and other important topics using BerniePortal’s comprehensive resources:

  • BerniePortal Blog—a one-stop-shop for HR industry news
  • HR Glossary—featuring the most common HR terms, acronyms, and compliance
  • HR Guides—essential pillars, covering an extensive list of comprehensive HR topics
  • BernieU—free online HR courses, approved for SHRM and HRCI recertification credit
  • HR Party of One—our popular YouTube series and podcast, covering emerging HR trends and enduring HR topics

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