February 1st means it is time, once again, to post Form 300A, your 2018 summary of work-related injuries and illnesses in the workplace. As part of the regulation, it must be prominently displayed from February 1st through the end of April each year.
Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. Posting this information fulfills a requirement of OSHA’s Recordkeeping Rule.
Why? This information helps: 1) evaluate the safety of a workplace, 2) understand industry hazards and 3) put in place worker protections aimed to prevent future workplace injuries and illnesses.
- Form 300: Log of Work-Related Injuries and Illnesses
- Form 301 Injury and Illness Incident Report
- Form 300A Summary of Work-Related Injuries and Illnesses
Electronic Submission of Records
On July 30, 2018, OSHA issued a Notice of Proposed Rulemaking to eliminate the requirement to electronically submit information from OSHA Form 300 and OSHA Form 301 for establishments with 250 or more employees that are currently required to maintain injury and illness records. These establishments would be required to electronically submit information only from OSHA Form 300A. In addition, OSHA is proposing to require covered employers to submit their Employer Identification Number electronically along with their injury and illness data submission.
Stay tuned and watch what happens prior to the March 2nd deadline.
Starting in 2019 and continuing for each year thereafter, organizations based on establishment size and NAICS code must submit 300A form data collected in the previous calendar year by March 2nd. The second part of the rule is the only part that has not yet taken effect, which is the requirement for large establishments with 250 or more employees to do more than the 300A. Keep posted to find out how the final rule takes effect.
What Can You Learn from Tracking This Data
Often what we find is that many workplace incidents are predictable and preventable. The goal with this regulation is to put you in the mindset of “prevention;” where you and your workers can find and fix potential problems before any injuries occur.
For instance, your 300A Log can help you identify potential hazards. For example, fall injuries may mean you need to review the types of fall protection or training you provide. MSD injuries may mean you need to improve ergonomic training.
Look for trends in your data: the types of injuries, the frequency, the types of machinery or processes involved.
Don’t forget to involve your workers when reviewing this data. They are doing the work day in and day out and typically will have lots of good ideas for improving the work process.