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.
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:
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.
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.
The situations above commonly arise at the end of each calendar year, along with many other questions. To help you avoid headaches when preparing your annual summary, our archived webcast from December 30, 2021, titled “Injury & Illness Recordkeeping: FAQ’s and Common Violations.” In addition to many frequent questions, we covered topics like posting obligations, e-reporting requirements, and calculating incident rates.