Attention Covered Employers: Form 300a workplace posting on February 1 still required!
If you thought everything changed with the COVID-19 pandemic, rest assured employers, your Cal/OSHA Form 300a Annual Summary of Work-Related Injuries and Illnesses workplace posting requirement must still go forward as usual.
Throughout the year, covered employers must maintain a Log of Work-Related Injuries and Illnesses on Form 300. To be recordable, an illness must be work-related and result in one of the following: (1) death; (2) days away from work; (3) restricted work or transfer to another job; (4) medical treatment beyond first aid; (5) loss of consciousness; (6) a significant injury or illness diagnosed by a physician or other licensed health care professional.
This includes COVID-19 related injuries and illnesses that meet one of the above criteria. The Form 300 Log of all work-related injuries and illnesses must then be summarized and tabulated on Form 300a.
The bottom line: All employers that are required to maintain injury and illness records must post their Form 300a summary on February 1, 2021, and keep it posted through April 30, 2021.
Here are the details:
· What must be posted? Employers need only post the Form 300a summary and not the entire Form 300 log.
· How do you add up total injuries? Using the Form 300 Log, count the individual entries you made for each category. Then write the totals in the Form 300a summary, making sure you have added the entries from every page of the Log. If you had no cases, write “0.”
· Certification: The injury and illness data must be certified on the 300a summary by a company executive.
· Where must the 300a summary be posted? The summary must be posted in a visible and easily accessible area of the workplace. A copy must be made to employees who do not regularly report to the workplace. Any current and former employee is entitled to a copy upon request. Cal/OSHA has not released specific guidance on posting the summary for employees working remotely due to the pandemic.
· Additional electronic reporting for some employers due March 2, 2021: In addition to the mandatory posting of Form 300a, some employers are required to submit their Form 300a data to federal OSHA. The following employers have this additional requirement:
o Employers with 250 or more employees, unless exempt under 8 CCR 14300.2
o Employers with 20-249 employees in Cal/OSHA Appendix H industries
· Record maintenance: Employers must retain Forms 300, 300a and 301 for 5 years.
For more detailed information on all posting/reporting requirements, you may visit Cal/OSHA’s Brief Guide to Recordkeeping Requirements or contact the experts at McKague Rosasco LLP.
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