It's that time of year OSHA season!
From February 1 through April 30 each year, companies covered by OSHA must post a summary of all work-related injuries and illnesses occurring at the workplace over the previous calendar year, using OSHA Form 300A, but your responsibilities as a safety pro don’t end there.
To complete the Form 300A, you will need to review all the entries in your injury log (the OSHA Form 300 Log) and enter a summary of the information onto the Form 300A. Once completed, a company official must certify Form 300A by signing it, and then post it in a prominent location where employees can see it. The posting is meant to make employees aware of the injuries and illnesses at their workplace.
OSHA's annual electronic submission requirement
Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from their 2020 OSHA Form 300A by March 2, 2021. This requirement also applies to establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. Trucking and other freight-moving industries are covered by this requirement. See the complete list of affected industries at: https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.html.
Three options are available for submitting the required data at OSHA’s “injury tracking application” (ITA) website (https://www.osha.gov/injuryreporting/index.html). Employers may:
- Manually enter data into a web form,
- Upload a CSV file to process single or multiple establishments at the same time, or
- Transmit data electronically via a programming interface.
Don't just fill out the form, use the information
When completing your Form 300A summary, be sure that all injuries and illnesses were investigated. An investigation should be extensive enough to determine a root cause and contributing factors. If an injury or illness was not investigated when it occurred, investigate it when you complete the 300A summary.
Once you’ve compiled the information on causes and contributing factors, determine whether there is something you can do to prevent future injuries. Common methods for preventing future injuries involve:
- Better education. Carriers might develop more effective training modules to address the work practice(s) or behavior(s) that led to the injury or illness.
- Better engineering. This involves designing a better “system” to prevent the injury or illness from happening in the future. This could involve improving (or implementing) policies and procedures, and/or providing the employees with better/safer equipment.
- Better enforcement. This may include enforcing existing policies and making sure that employees are following the procedures and practices you have in place.
Key to remember: If you do nothing to change knowledge, systems, or people, you will continue to get the same results. Use the OSHA 300A process to make your workplace a safer one.