Posting the 2011 OSHA Summary

Employers, it is almost that time of year again; are you prepared to post your 2011 OSHA Summary on February 1st?

According to Occupational Safety and Health Administration (OSHA) Recordkeeping Guidelines, a current OSHA Summary (not the OSHA 300 Log) must be posted in your workplace location(s) annually by February 1ST until April 30th. The Summary, Form 300-A, must be posted in a visible location accessible to all employees in each establishment or site. Form 300-A reports the total number of job-related injuries and illnesses, number of deaths, missed workdays and job transfers or restrictions that occurred in the previous year. Companies with no recordable injuries or illnesses in 2011 must post the form with zeros on the total line.

 Employer’s Responsibilities Regarding the Annual Summary

  • Posting: The Annual Summary (Form 300-A) must be posted in an area where it cannot be altered, defaced or covered by other material. Employers can also distribute copies of the summary to employees who move from worksite to worksite, such as construction workers and employees who do not report to a fixed location on a regular basis.
  • Certification: Prior to posting, the Annual Summary must be reviewed by a company executive certifying that he or she has examined the report and has reasonable belief that the Annual Summary is correct and complete, based on his or her knowledge of how the information was recorded. OSHA implements the “senior management accountability” requirement to ensure the integrity and accuracy of the report. Four specific management positions are identified to serve as “company executive” for purposes of certifying the Annual Summary.
    • An owner of the company;
    • An officer of the corporation;
    • The highest ranking company official working at the establishment; or
    • The immediate supervisor of the highest ranking company official working at the establishment.

Employer’s Responsibilities regarding OSHA Reports

  • Retention: Employers must save the OSHA 300 Log, the annual summary and the OSHA 301 Forms or the equivalent SCI form #1020-Incident Investigation Report form for five (5) years following the end of the calendar year that these records cover.
    • OSHA Part 1904: When an authorized government representative asks for the records kept under OSHA Part 1904, Employers must provide copies of the records within four (4) business hours. The government representatives authorized to receive the records are:
      • A representative of the Secretary of Labor conducting an inspection or investigation under the Act;
      • A representative of the Secretary of Health and Human Services (including the National Institute for Occupational Safety and Health – NIOSH) conducting an investigation under section 20(b) of the Act; and/or
        • A representative of a State agency responsible for administering a State plan approved by OSHA.
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