REMINDER – the OSHA 300A Form posting deadline is approaching.  The OSHA Record Keeping Rule requires employers keep records of all work-related injuries and illnesses.  This includes the OSHA 300, 300A and the First Report of Injury that employers must have on file.  If you do not already have copies of these forms, they can be accessed through this link OSHA Recordkeeping Forms and Instructions.  The 300A Summary of Injuries and Illnesses is the only form that must be posted from February 1 to April 30 of each year.  The 300A must be posted in a common area where notices to employees would normally be posted. Be sure to post this form beginning February 1, 2022.

It is very important that the OSHA 300A Summary be filled out completely and correctly.  If there were no work-related accidents to report, the form must be filled out with zeros in each blank.  Many employers often overlook the “Establishment Information” portion of the form or just do not sign it.  One area of the establishment information that creates some confusion is the “average number of employees”.  The average number of employees is simply the total number of paychecks written to ALL employees during the year divided by the total number of pay periods in the year.  The paycheck number should include all full-time, part-time, temporary, migrant, salaried, and hourly employees for the entire year.

The other form found at the link above is the OSHA 300 Log of Work-Related Injuries and Illnesses.  This is a log containing information about every work-related death and almost every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, and/or medical treatment beyond first aid. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.  It is also important to completely fill out the OSHA 300 form. All columns must be totaled even if you had no accident to report.  The information from the OSHA 300 form is used to complete the OSHA 300A form.

It is also a good idea to calculate your Injury and Illness Incidence Rate on the OSHA 300A form.  You will need this later for the Electronic Submission.  If you have a DART Incidence rate that is very high, OSHA may have some interest in your operation.  Part of this calculation uses the total number of hours worked by ALL employees.  Be sure to include ALL employees (hourly, seasonal, salaried, etc.).  Estimate salaried hours if needed.  The higher the hours worked are, the lower the DART rate is so be sure you include all hours worked by all employees.

This is also a good time to enter your 2021 Injury and Illness data on the OSHA Web Portal.  Any cotton gin employer with 20 or more employees at any time during the calendar year is required to enter this data electronically.  The data entered electronically is essentially the same data contained in the OSHA 300A form.  The deadline for electronic submission is March 2, 2022.  To access the electronic submission portal simply click this link OSHA Electronic Submission Page

Please review this information and contact the association if you have any questions about reporting and posting so you are following OSHA’s Recordkeeping Standard.  If OSHA comes to your facility for an inspection, they will ask to see the OSHA 300 and 300A forms going back for a period of 5 years.  They will also expect to see the OSHA 300 form partially filled in for the current year.  It is important to have the files and data on hand and easily accessible.  More information regarding OSHA Recordkeeping can be accessed through OSHA Recordkeeping Rule as well as the TCGA Website.