OSHA 300A Summary must be posted in workplace Feb.1 through April 30, 2023

OSHA’s Recordkeeping Standard, 29 CFR 1904, requires that certain employers maintain annual records of workplace injuries and illnesses. Records of workplace injuries and illnesses are maintained throughout the calendar year on the OSHA Form 300 Log of Work-Related Injuries and Illnesses (300 Log) and are summarized on the OSHA Form 300A Summary of Work-Related Injuries and Illnesses (300A Summary) at the end of each calendar year. The 300A Summary is required to be posted in the workplace every Feb. 1 through April 30 to show records from the previous year’s injuries and illnesses, even if no work-related injuries or illnesses occurred during the previous year.

Helping your company comply with OSHA regulations is one of the key benefits of ADP TotalSource®. If your company is not partially exempt (either by industry, size, or both) from OSHA recordkeeping requirements, ADP will help you fulfill this responsibility by providing your company with its preliminary 300 Log and 300A Summary at the end of January each year. The preliminary 300 Log and 300A Summary are available through your ADP TotalSource website. Please see access instructions below.

As the employer, you may need to take additional steps to ensure your 300 Log and 300A Summary fully capture the information required by OSHA. The preliminary 300 Log and 300A Summary are based on workers’ compensation data reported to TotalSource and may not contain all the information necessary to complete the 300 Log and 300A Summary. The preliminary 300 Log, for example, may be missing adequate details describing the injury or cause of injury because that information was not provided when the injury or illness was reported.

Additionally, since workers’ compensation and OSHA recordable injuries are not directly correlated, there may have been injuries at your workplace that were not reported to workers’ compensation or denied by workers’ compensation that should be included on your 300 Log and 300A Summary. For example, OSHA requires that controlling record data for injuries and illnesses for temporary employees and sub-contracted employees used by those employers. TotalSource does not have access to temporary and/or sub-contracted employee injury and illness data and, as such, it will not be included on your preliminary 300 Log and 300A Summary.

New enhancements to ADP TotalSource reporting

Users now can edit, save and print a copy of the 300 Log and 300A Summary. Select one location at a time to be able to access the edit features.
Additional helpful features coming soon! Log into ADP TotalSource regularly to learn what’s new.

Recording workplace exposures to COVID-19

COVID-19 can be a recordable illness if a worker is infected as a result of performing his or her work-related duties. However, employers are only responsible for recording cases of COVID-19 if all the following are true:

1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
2. The case is work-related (as defined by 29 CFR 1904.5); and
3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

Employers should follow the OSHA enforcement guidance found in the Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19)

PureSafety course available on myLearning@ADP

The course “OSHA 300 Recordkeeping Requirements” is available on-demand through ADP’s learning management system, myLearning@ADP for free! Access to myLearning@ADP is through your ADP TotalSource website.

How to access preliminary OSHA 300 Log and OSHA 300A Summary in ADP TotalSource

1. In ADP TotalSource, select ‘Reports & Analytics’ > ‘Reports Dashboard‘
2. In the Reports Dashboard click on ‘OSHA Reports’ under Additional Reporting Links
3. Select Company Code, location/establishment, and year 2022 from drop down menus
4. Click ‘Generate OSHA Reports’
5. Download and review reports
6. Print and sign both reports
7. Post OSHA 300A Summary

FAQs

Do I need to maintain records for injuries or illnesses in my workplace?

Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. To find out if you are required to prepare and maintain records, first determine your company’s NAICS code. Certain low-risk industries are exempted. 

How long must I retain OSHA recordkeeping records?

The records must be maintained at the worksite for at least five years.

What if an employee asks for OSHA recordkeeping record?

If requested, copies of OSHA recordkeeping records must be provided to current and former employees, or their representatives.

What is the severe injury reporting requirement?

Employers must report to OSHA any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization or a worker within 24 hours.

Who is covered by the electronic reporting requirement?

Only a small fraction of establishments is required to electronically submit their Form 300A data to OSHA. Establishments under Federal OSHA jurisdiction can use the ITA Coverage Application to determine if they are required to electronically report their injury and illness information to OSHA. Establishments under State Plan jurisdiction should directly contact their State Plan.

Establishments that meet any of the following criteria DO NOT have to electronically report their information to us. Remember, these criteria apply at the establishment level, not to the firm as a whole.

• The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
• The establishment's industry is on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the size of the establishment.
• The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.

Where can I learn more about OSHA recordkeeping?

Please visit this webpage: http://www.osha.gov/recordkeeping

Questions

If you have any questions about the information on your preliminary OSHA 300 Log or 300A Summary and/or would like additional guidance on OSHA recordkeeping requirements, such as partial exemptions, please contact your TotalSource Risk and Safety Consultant for assistance.