From February 1 to April 30, 2023, OSHA requires employers, who are required to keep OSHA logs, to post their OSHA summary (Form 300A) during the required posting period for the 2022 calendar year. You may view the Partially Exempt Industries list here.
The summary log must be posted on premises where all employees/visitors can readily view the document. The summary log has been modified to omit certain information such as names of the injured employees and other personal information. If you have multiple locations,
a copy must be posted at each site for injuries occurring at that location.
OSHA has instructions and forms on their website that you can access here.
You may also download the following documents:
OSHA 300, 300-A and 301 Logs (Please note that all three forms are in multiple tabs within the same spreadsheet).
OSHA 300A Annual Summary, Management Handout
Please remember that you can be fined for failing to post the OSHA log. The exemptions include retail, service, finance, real estate, schools, and doctors and dental offices. See the California Standard Exemptions to the posting requirements for a complete description of exemptions.
300A Electronic Submission:
March 2, 2023, is the deadline for electronically reporting your OSHA Form 300A data for the calendar year 2022.
The collection will begin on January 2, 2023. The collection of 2022 data and beyond will include the collection of establishments’ Employer Identification Numbers (EIN). The OSHA Injury Tracking Application (ITA) has transitioned its login protocol to the public’s one account access to government applications at Login.gov. All current and new account holders must connect their ITA account to Login.gov account with the same email address to access the application for the 2023 collection of Calendar Year Form 300A data. Click here to view an instructional video on how to access your Login.gov account.
Who must file electronically?
Establishments with 250 or more employees.
Establishments with 20 to 249 employees in high-risk industries listed by NAICS codes.
OSHA has amended its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees which are required to keep injury and illness records routinely. These establishments are still required to electronically submit information from OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Here is the OSHA trade release letter regarding the U.S. Department of Labor Issues Final Rule to Protect Privacy of Workers.
Review the Injury Tracking Application web page for instructions and frequently asked questions.
Recording workplace exposures to COVID-19
COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all the following are true:
- The case is a confirmed case of COVID-19 (see CDC informationon persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
- The case is work-related (as defined by 29 CFR 1904.5); and
- The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7(e.g., medical treatment beyond first aid, days away from work).
Note: On December 15, 2022, the Occupational Safety and Health Standards Board voted to adopt non-emergency COVID-19 prevention regulations. These regulations will take effect once they are approved by the Office of Administrative Law (OAL) in the month of January 2023 and will remain in effect for two years after the effective date, except for the recordkeeping subsections that will remain in effect for three years. Once they are approved employers will still need to maintain records of COVID-19 cases and immediately report serious illnesses to Cal/OSHA and to the local health department when required. Outbreaks will also need to be reported to Cal/OSHA. What employers need to know.
For more information, please visit the OSHA FAQ page or www.osha.gov and COVID-19 – Regulations.
You may also contact Laurie Flores at lflores@boltonco.com with questions.
While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting, or other professional advice or services. Readers should always seek professional advice before entering any commitments.
