Categories: OSHA

February 1st is an important annual OSHA Injury and Illness Recordkeeping deadline for all U.S. employers, except for those with only ten or fewer employees or who operate in enumerated low hazard industries such as retail, service, finance, insurance or real estate (see the industries partially exempted from OSHA's Injury & Illness Recordkeeping regulations at Appendix A to Subpart B of Part 1904).  Specifically, by February 1st every year, employers are required

by OSHA’s Recordkeeping regulations to:

  1. Review their OSHA 300 Log;
  2. Verify that the entries are complete and accurate;
  3. Correct any deficiencies on the 300 Log;
  4. Use the injury data from the 300 Log to develop an 300A Annual Summary Form; and
  5. Certify the accuracy of the 300 Log and the 300A Summary Form.

The Form 300A is a summation of the workplace injuries and illnesses recorded on the OSHA 300 Log during the previous calendar year, as well as the total hours worked by all employees covered by the OSHA 300 Log that year.

The 300 Log and the 300A Annual Summary Form are required to be “certified” by a “company executive,” including a signature by the company executive on the 300A Summary Form.  A common mistake that employers make is to have someone sign the 300A Form who is not at a senior enough level to constitute a “company executive.”  The company executive who must certify the 300A must be one of the following:

  • An owner of the company (only if the company is a sole proprietorship or partnership);
  • An officer of the corporation;
  • The highest ranking company official working at the establishment; or
  • The immediate supervisor of the highest ranking company official working at the establishment.

What it is that the company executives are certifying is that they have examined both the OSHA 300 Log and the 300A Annual Summary Form, and that they reasonably believe, based on their knowledge of the process by which the information was recorded, that the 300A Annual Summary Form is correct and complete.

After certifying the recordkeeping documents, OSHA’s Recordkeeping regulations require employers to post the signed copy of the 300A Summary Form in the location at the workplace where employee notices are usually posted.  The 300A must remain posted there for three months, through April 30th.

Another common mistake employers make is to not prepare or post a 300A Form if there were no recordable injuries or illnesses during the year.  In that instance, OSHA regulations still require employers to completely fill out the Form 300A, enter zeros for each column total, and post the 300A just the same.

After April 30th, employers can take down the 300A Form, but must keep (at a central location or at the facility to which the forms apply) a copy of the OSHA 300 Log, the 300A Annual Summary Form, and any corresponding 301 Incident Report forms for five years following the end of the calendar year that those records cover.  Here are exemplars of all the OSHA Recordkeeping forms.

One more common mistake employers make is to put away the old 300 Logs, and never look back, even if new information comes to light about injuries recorded on those logs.  OSHA’s Recordkeeping regulations require employers to update OSHA 300 Logs with newly discovered recordable injuries or illnesses, or to reflect changes that have occurred in the classification or other details of previously recorded injuries and illnesses during the five year retention period.  Note, this requirement applies only to the 300 Logs; there is no duty to update 300A Forms or the OSHA 301 Incident Reports.

EBG’s OSHA Injury and Illness Recordkeeping Checklist is a great resource to consult when annually reviewing, verifying, and certifying your Recordkeeping logs and forms.

Back to Workforce Bulletin Blog

Search This Blog

Blog Editors

Related Services



Jump to Page


Sign up to receive an email notification when new Workforce Bulletin posts are published:

Privacy Preference Center

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.