End of year FAQs on recordkeeping and the 300A

At the end of each calendar year, a number of questions arise regarding the OSHA 300A Annual Summary. The following answers common questions that you may face at this time of year.

Review the 300 Log

Before creating the summary, OSHA says to review the 300 Log to for accuracy. This does not mean you must examine every entry. However, you should spot check a number of cases. Here are some things to check:

• Column (E) lists the injury location. Just writing “warehouse” usually isn’t good enough. Provide as much description as you can. This doesn’t affect the summary, but it’s a good review in case OSHA reviews your records during an inspection.
• Column (F) describes the injury, body part, and cause of the injury. A common error is listing an injury and body part (like “fractured forearm”) but missing the cause. Also, in this example, specify the left or right forearm.
• Some entries may show more than one injury type, such as “days away” and “restrictions.” Software should not allow this, but it can happen with paper forms.

One location, one 300A

Every establishment required to create a 300 Log must maintain a log for each location. If you have five locations, you need a 300 Log for each one. You may keep records at a headquarters, but you must be able to pull the data for a single location on request, like during an OSHA inspection.

At the end of the year, create a summary (300A) for each establishment. That summary must show only the data for that location, and must be posted in the establishment from February 1 through April 30.

Closed or opened a location

During the last year, you might have closed (or sold off) one or more locations. If so, you don’t have to create an annual summary. There would be no place to post it anyway. Also, if a closed establishment was supposed to electronically submit the 300A to OSHA by March 2nd, you are free of that obligation as well.

If your company acquired a new location, the previous owner must transfer the 300 Logs to you. However, you do not have to update the transferred logs. Also, if you need to create a 300A or electronically submit the 300A, you only have to use data for the portion of the year that you owned the establishment.