OSHA Form 300A Posting Requirement

By Tim Karcz, Senior Risk Manager

The Occupational Safety and Health Administration (OSHA) requires employers to post OSHA Form 300A between February 1 and April 30, 2021. Form 300A provides a summary of the total number of job-related injuries and illnesses that occurred in 2020 and were logged on OSHA Form 300. The form must be posted in a location where employee notices are usually found, and must not be altered, defaced, or obscured during the posting period.

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A copy of Form 300A must also be made available to employees who do not report to any fixed establishment on a regular basis.  At the end of the three-month posting period, the Form 300A should be kept on file for five years.  If any newly discovered, recordable incidents or changes in classification are noted, the log should be updated.

Employers must record any new work-related injury or illness if it results in days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, significant injury or illness as diagnosed by a physician or other licensed healthcare professional, or death. Employers must record any incidents that aggravate a prior injury. Employers are also required to log COVID-19 related illnesses on the form.

OSHA has strict requirements for protecting the privacy of injured and ill employees. An employer shall not record the employee’s name on the OSHA 300 log for certain “privacy concern cases.” Instead, “Privacy Case” shall be entered in the space reserved for the employee’s name. OSHA defines a privacy concern case as an injury or illness to an intimate body part or the reproductive system; an injury or illness resulting from a sexual assault; mental illnesses; HIV infection, hepatitis, or tuberculosis; needle stick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material; and other illnesses if the employee voluntarily requests that his or her name not be entered on the log. The Authority is recommending that all cases reference “Privacy Case” in the employee name fields, not just in privacy concern cases as defined by OSHA.

Members who participate in the Authority’s Workers’ Compensation Program recently received an email from Sedgwick with a partially completed Form 300A with instructions for completing and posting the form.  Members should follow the instructions and post a copy of the completed form by February 1, 2021. Forms 300 and 300A can also be obtained from the Cal/OSHA website.

For more information, please contact your assigned Risk Manager.

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