It’s that time of year again!  Employers covered by OSHA’s recordkeeping rule must prepare and post the OSHA Form 300A "Summary of Work-Related Injuries and Illnesses" by February 1 and keep the form posted until April 30.  The form must be posted at each establishment covered, in a conspicuous place where notices to employees are customarily posted.

After the form is completed, but before posting, a company executive must also certify that "he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knoweldge of the process by which the information was recorded, that the annual summary is correct and complete."

Under OSHA’s rule, a company executive can be one of the following:

  • an owner of the company (only if the company is a sole proprietorship or partnership);
  • 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.

This obligation is important and employers can be cited for failure to post.  Employers should take steps now to make sure they are fully compliant.