OSHA requires annual posting of injury and illness data. Cotton gins, grain, feed and processing facilities are required to complete the Occupational Safety and Health Administration’s (OSHA) injury and illness record-keeping obligations by posting the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A) in each facility. OSHA requires the notice be displayed from Feb 1 – Apr 30 each year in a visible place where employee notices are usually posted. Businesses with no injuries or illnesses for the year are required to post the form as well. In addition, a company official is required to certify that the information in Form 300A was checked and is believed to be correct and complete. You can access the OSHA 300/300A forms and instructions at the following link (Forms & Instructions) or by visiting the “Safety and OSHA Resources” section under Member’s Only on the TCGA website.
All the accident information for the OSHA 300A should come from your OSHA 300 form that you maintain throughout the year. Be sure to record accidents on your OSHA 300 that are required to be reported. Accidents reported to your Worker’s Compensation carrier MAY or MAY NOT be required to be reported on your OSHA 300. Accidents required to report for OSHA include:
- Loss of Consciousness
- Days Away from Work
- Restricted Work Activity or Job Transfer
- Medical Treatment beyond First Aid
- Significant Injury Diagnosed by a Physician
- Fractured or Cracked Bone
- Puncture of an Eardrum
Employment information is required in the OSHA 300A report. This information is very important because it is used to calculate DART and Incidence rates for your facility. One of the questions requires the “Average Number of Employees”. Do not estimate this number. The correct way to calculate this is to count the total number of paychecks issued throughout the year and divide that number by the total number of pay periods (i.e. 52 if you pay weekly). If you use the maximum number of employees you had during the season, this can inadvertently increase your DART rate.
The “Total hours worked for all employees” is also required. Calculate this number for all the employees on staff throughout the year including office staff and salaried gin staff. It is acceptable to estimate the salaried hours. Simply keep a note on how they were determined.
Finally, employers with 20 to 250 employees – in each establishment – are required to electronically submit their 300A form annually (includes part-time, seasonal, and/or temporary workers). This means you wrote checks for more than 20 employees in any given pay period. Since this last season was not a large production year, some facilities may be below this number this season even if they were above 20 employees in prior years. If you are below the 20-employee threshold, you DO NOT need to submit the electronic version. It is recommended you keep a note documenting this in your OSHA files. If you do meet this threshold, you must submit the OSHA Form 300A information using the (Injury Tracking Application) on OSHA’s website by March 2. Employers also are required to include their Employer Identification Numbers (EIN) when filing their reports.
Recently, OSHA revised some of the annual reporting rules. Individual facilities with more than 100 employees are required to add additional information to their annual reports. This includes information from the OSHA 300 and the OSHA 301 (First Report of Injury). If you think you may be subject to this portion of the rule, please contact our office and we can discuss.
As always, if you have any questions about OSHA reporting or any other topic, please contact the TCGA office and we will be glad to assist you.