Staying Up-to-Date with OSHA 300 Logs

Author, Jadyn Brandt, Client Communications Coordinator, Rancho Mesa Insurance Services, Inc.

Employers who maintain accurate OSHA logs not only avoid costly fines but also gain valuable insights into workplace safety trends by identifying hazards early and in real-time, thus strengthening the effectiveness of their safety programs.

Under OSHA’s recordkeeping regulations, employers with more than 10 employees in designated industries are required to keep detailed records of injuries and illnesses that occurred on the job. Often referred to as OSHA logs, these records include OSHA Forms 300, 300A Summary and 301.

OSHA Logs

OSHA Form 300

The OSHA Form 300 is a list of each occupational injury or illness and basic details including the employee’s name, job title, date of injury or illness, location and a brief description. The 300 log shall also include the seriousness of the injury or illness, the number of days the employee was away from work or was transferred as a result of the injury or illness, and the category of the incident.

OSHA Form 300A Summary of Work-Related Injuries and Illnesses

The OSHA Form 300A is a summary of the workplace injuries and illnesses that are listed on the Form 300 for the calendar year. The summary does not include any personal data such as employee names or incident descriptions. This is the document that will need to be posted in your workplace.

OSHA Form 301

Each injury or illnesses listed on the Form 300 must have a corresponding Form 301. The Form 301 includes specific information describing how the injury or illness occurred. Employers do not need to submit this form to OSHA, however, they must keep Form 301 in their records for at least five years after the incident occurs.

Posting Deadline – February 1st through April 30th

OSHA 300A Summary

Employers will need to post OSHA Form 300A in “a conspicuous place or places where notices to employees are customarily posted,” (1904.32 (b)(5)) between February 1st and April 30th each year. Be sure that the annual summary is not altered, defaced, or covered by other material throughout the posting period.

Submission Deadlines – March 2nd

OSHA 300A

Employers with 20 - 249 employees in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904 or employers with 250 or more employees who are not listed in the Exempt Industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904 are required to submit the information from the OSHA Form 300A by March 2nd.

OSHA Forms 300 and 301

Employers with 100 or more employees and is in the industry listed in Appendix B to Subpart E of 29 CFR Part 1904 must submit the information from Form 300/301 to federal OSHA via the ITA by March 2nd.

Submissions must be posted through federal OSHA’s online Injury Tracking Application (ITA) website or your state’s own reporting mechanism if applicable.

Rancho Mesa Resources

Rancho Mesa has a number of resources available for employers who want to stay up-to-date with their OSHA logs.

Injuries and illnesses can be documented via the SafetyOne™ mobile app or QR code-accessible mobile forms to satisfy the Form 301 requirement. Clients can also complete the OSHA Form 300 with each injury or illness case and download/print  the Form 300A Summary using the RM365 HR Advantage portal™.

For more information on how to manage OSHA logs requirements in SafetyOne and the RM365 HRAdvantage Portal, register for Rancho Mesa’s on-demand OSHA Recordkeeping and Annual Reporting Webinar.

Google AI shows “10 or more employees” but if you read the actual requirement, it says “10 or fewer employees.” So, employers with more than 10 employees are required to keep the OSHA logs.

This is not correct. The 300A is just totals of all injuries and illnesses from the 300.

It’s OSHA 300A Time

Author, Emily Marasso, Media Communications Assistant, Rancho Mesa Insurance Services, Inc.

The holidays have come and gone and here we are at the end of another great year. Year-end means calendar updates, process changes and document reviews, as well as time to prepare for filing your OSHA 300A form. 

The OSHA 300A form is a summary of injuries and illnesses which occurred on the job during the calendar year. The form must be filed electronically on the Injury Track Application (ITA) starting January 2, 2020. Deadline for 2019 data submissions is March 2, 2020. It must be displayed from February 1, 2020 to April 30, 2020.

Don’t forget, if you are a Rancho Mesa client and utilize the Risk Management Center Incident Track feature, you have access to generate the Cal/OSHA 300A form and export it to a CSV file. From there you can upload it to the OSHA website.

Rancho Mesa has put together a 5-minute tutorial video on how to generate the electronic 300A form data file from the Risk Management Center, that can be uploaded to the Injury Tracking Application website for reporting the data.

For questions about how to track the injury and illness data in the Risk Management Center, contact Alyssa Burley at (619) 438-6869.

OSHA Amends Electronic Submission Requirements to Exclude Forms 300 & 301

Author, Lauren Stumpf, Media Communications Assistant, Rancho Mesa Insurance Services, Inc.

OSHA published a final rule through the Federal Register on January 25, 2019 stating, “To protect worker privacy, the Occupational Safety and Health Administration (OSHA) is amending the recordkeeping regulation by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 and 301.”

All establishments with 250 or more employees, unless specifically exempted by section 14300.2 of title 8 of the California Code of Regulations, and establishments with 20 to 249 employees in the specific industries listed in Appendix H of Cal/OSHA's emergency regulations are still required to electronically submit the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this final rule. This final rule becomes effective on February 25, 2019.

The deadline to electrically submit the 2018 Form 300A is March 2, 2019.

Rancho Mesa has put together a 6-minute tutorial video on how to generate the electronic Form 300A data file from the Risk Management Center, that can be uploaded to the ITA website for reporting the data.

For questions about how to track the injury and illness data in the Risk Management Center, contact Alyssa Burley at (619) 438-6869.

Sources:
https://www.osha.gov/recordkeeping/
https://www.dir.ca.gov/dosh/calosha-updates/log300-reporting.html
https://www.federalregister.gov/documents/2019/01/25/2019-00101/tracking-of-workplace-injuries-and-illnesses

Cal/OSHA Issues Electronic Filing Requirement For 2017 OSHA 300A Form

Author, Alyssa Burley, Client Services Coordinator, Rancho Mesa Insurance Services, Inc.

In April 2018, federal OSHA announced all affected employers are required to submit injury and illness data (i.e., Form 300A data) via the Injury Tracking Application (ITA) online portal by July 1, 2018, even if the employer is covered by a state plan like those in California, Maryland, Minnesota, South Carolina, Utah, Washington or Wyoming.

Cal/OSHA then issued a statement in May 2018, advising affected employers “to comply with federal OSHA’s directive to provide Form 300A data covering calendar year 2017," even though it was not a Cal/OSHA requirement.

“On November 1, 2018,” according to the Cal/OSHA website, “the Office of Administrative Law approved the emergency action. This means that the employers in California described below are now required to submit Form 300A data covering calendar year 2017 by December 31, 2018. These employers should follow the instructions posted at federal OSHA's ITA website:

Check Appendix H for your industry. It includes industries like: Construction; Community/Nursing/Residential Care facilities; Community Food/Housing Relief Services; and many more.

• All employers with 250 or more employees, unless specifically exempted by section 14300.2 of title 8 of the California Code of Regulations

• Employers with 20 to 249 employees in the specific industries listed in Appendix H of the emergency regulations.”

This emergency action by the Office of Administrative Law brings Cal/OSHA’s requirements up to the federal OSHA’s minimum standards, with one difference. Federal OSHA required affected employers covered by state plans to submit the 2017 Form 300A data electronically by July 1, 2018, while this new action requires affected California employers to submit the data by December 31, 2018.

Since the Federal OSHA deadline has already passed, it is recommended that all affected employers in California who have not already submitted the 2017 Form 300A data via the ITA, submit it as soon as possible, but no later than December 31, 2018.

Next year, the deadline for electronically submitting 2018 Form 300A data will be March 2, 2019.

Rancho Mesa has put together a 9-minute tutorial video on how to generate the electronic Form 300A data file from the Risk Management Center, that can be uploaded to the ITA website for reporting the data.

For questions about how to track the injury and illness data in the Risk Management Center, contact Alyssa Burley at (619) 438-6869.

OSHA Not Prepared to Accept Electronic Submissions

Author, Alyssa Burley, Client Services Coordinator, Rancho Mesa Insurance Services, Inc.

For over a year, the Occupational Safety and Health Administration (OSHA) have championed the upcoming electronic submission of injury and illness records (i.e., OSHA 300 logs) through its website.  The new requirement was designed to make OSHA records publicly available on the internet in hopes that it would encourage employers to maintain safer working environments.  The electronic submissions of the 2016 reports were supposed to be due by July 1, 2017.

However, in a mid-May announcement, the government agency’s website declares “OSHA is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically.”

According to an article on Front Page News, “several business groups, including the Associated Builders & Contractors, Association of General Contractors, and National Association of Home Builders, had challenged the 2016 Occupational Safety and Health Administration regulation in court and lobbied the administration to jettison it on grounds that it could unfairly damage the reputation of some of their members.”

In preparation of the anticipated electronic submission requirement, developers of Rancho Mesa’s Risk Management Center, an online platform designed for risk management, workplace safety and compliance have been ready and waiting for the details of OSHA’s API (application programing interface) in order to build a seamless integration between the two websites. Rancho Mesa will keep its clients up to date on the development of this integration, if and when it becomes operational on the OSHA website.

As for now, Rancho Mesa is urging its clients to continue to track incidents in the Risk Management Center so they may take advantage of its trending tools and reports.

For details regarding who must keep and report OSHA records, visit www.osha.gov/injuryreporting.

Sources: 
“Injury Tracking Application: Electronic Submission of Injury and Illness Records to OSHA.”  United States Department of Labor. Retrieved from: https://www.osha.gov/injuryreporting/.
“OSHA suspends rule requiring firms report injury, illness data electronically.” Front Page News.  Retrieved from: http://www.advisen.com/tools/fpnproc/news_detail3.php?list_id=26&email=kvasquez@ranchomesa.com&tpl=news_detail3.tpl&dp=P&ad_scale=1&rid=283636777&adp=P&hkg=5cY58Bd37J