Preparing for OSHA Recordkeeping in the New Year

As we begin 2025, it’s the perfect time to reflect on the past 12 months and prepare for what’s ahead. For compliance professionals, this means reviewing our calendars to ensure we’re on track with the necessary steps to maintain operations in good standing with regulators.

For many employers with ten or fewer employees in certain low-risk industries, you may be exempt from submitting the OSHA Log & Summary. However, for employers with more than 10 employees, it’s time to comply with one of OSHA’s recordkeeping requirements: reviewing your Work-Related Injuries and Illnesses Logs (Form 300) and preparing for the annual submission and posting of the OSHA Form 300-A Summary as outlined in 29 CFR 1904.32. Here’s a quick guide to ensure compliance:

STEPS FOR COMPLIANCE

Access the Required Forms

  • If you don’t have them, OSHA provides downloadable, fillable .PDF forms for maintaining your Work-Related Injuries and Illnesses Logs. While you may use an equivalent format (Excel, CSV, etc.), it’s easier to use what’s available. Here are the links to the forms:
    • English (Forms 300, 300A, 301 with instructions)
    • Español (Forms 300, 300A, 301 only)
    • Note: Some states (like California and Oregon) have their own OSHA 300 log forms. Be sure to verify and comply with your state’s specific requirements.

Review Your OSHA 300 Log

  • Carefully double-check that all records are complete and accurate. Inaccurate or missing data could lead to compliance issues.

Prepare Your Annual Summary

  • Understand the key points for your Form 300-A Summary, including:
    • When injuries and illnesses are considered work-related
    • Which cases must be recorded
    • What counts as medical treatment vs. first aid
    • How to calculate restricted duty and days away from work
    • When to use an employee’s name and how to make corrections
    • Correctly classifying illnesses

Finalize and Certify the Summary (Form 300-A)

  • Ensure that the Form 300-A is complete, accurate, and signed by a company executive. This certification is a crucial step for compliance.

Post the Summary (Form 300-A)

  • Display the Form 300-A Summary page (or your state’s equivalent) in a visible, accessible location for all employees from February 1st through April 30th, 2025.
    • Note: You should only post the 300-A Summary, not the full 300 Log.
  • Employers may also need to submit Form 300-A to OSHA electronically. To determine if this applies to your business, visit OSHA’s Injury Reporting Page.

Retain Records for Five Years

  • OSHA requires that you retain your records on file for a minimum of five years for compliance.
    • Note: Even if no recordable injuries occurred, the log must still be reviewed, summarized, signed by an executive, and posted as described.

Staying ahead of your compliance responsibilities now can save you time and reduce the risk of issues later. For more detailed information, visit the Injury and Illness Recordkeeping and Reporting Requirements page.

If you have any questions or need assistance, Ingenium’s EHS INTO COMPLIANCE consulting team is available to assist, so please reach out!

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