7015 College Blvd
Suite 375
Overland Park, KS 66211

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OSHA’s New Reporting Requirements Are In Effect

By Katherine Tracy

As of January 1, 2015, the Occupational Safety and Health Administration’s (“OSHA”) new reporting rules went into effect. The new rules require employers to contact OSHA within 24 hours of any in-patient hospitalizations, amputations, or loss of an eye. The 24-hour notification is in addition to the current requirement to contact OSHA within 8 hours following a fatality.

Additionally, there are also new record keeping and posting requirement. There are new categories of employers that must now maintain and post OSHA injury and illness records – 25 industries previously exempt must ow comply. Employers must utilize form 300A to comply with OSHA’s posting requirements and must complete the 300 logs and post the 300A summary even if the employer has not had a recordable injury or illness (zeros should be included to demonstrate no injury or illness). The annual summary includes a calculation of the annual average number of employees covered by the log and the total hours worked by all covered employees.

OSHA requires that a company executive – an owner, officer, highest-ranking company official working at the business location or the highest-ranking official’s immediate supervisor – certify the 300A summary. The certification requires the company executive to review the OSHA 300 logs and related records, and certify that he or she reasonably believes that the posted summary is accurate and complete. The company records should be reviewed as “extensively as necessary” to ensure the accuracy of the summary. Even minor errors will catch the attention of OSHA investigators.

Now that you have the summary, make sure to post it in a conspicuous place in each establishment where notices to employees are customarily posted, such as where wage and hour and anti-discrimination posters are posted. The summary must not be altered or hidden in any way and the employer will need to re-post the summary if it is damaged, defaced or hidden in any fashion – or an employee takes it upon himself or herself to add their own graffiti to the summary.

To establish that an employer properly posted the summary, those employers maintaining the summary in electronic form should keep the signed posted summary after the posting period ends on April 30. Additionally, any employees who may not see the summary (i.e., they work outside the location where the summary is posted), should be provided with a copy.

Keep the records for 5 years plus the current year for OSHA to review upon request. OSHA is picky and will look very closely at the summary for even minor errors.

Don’t forget – under OSHA’s new rule, 25 industries are no longer exempt from providing the summary and 300 logs. Are you one of those employers? Make sure to review the updated industry exemption list to see if you are now covered under the new rule.

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7015 College Blvd, Suite 375 — Overland Park, KS 66211


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    7015 College Blvd
    Suite 375
    Overland Park, KS 66211