^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ THIS WEEK'S TIP: Stay on Top of OSHA Posting Requirements It's time to comply with OSHA's annual illness and injury posting requirements once again. This year make sure you break out any hearing loss cases on Form 300A.

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THIS WEEK'S TIP: Stay on Top of OSHA Posting Requirements Do you have your Occupational Safety and Health Administration (OSHA) Form 300A posted? Should you? Covered employers are required to post the form, a Summary of Work-Related Injuries and Illnesses, from February 1 until April 30 each year. Form 300A reports your total number of deaths, missed workdays, job transfers or restrictions, and injuries and illnesses as recorded on Form 300 (the Log of Work-Related Injuries and Illnesses). Form 300 must be maintained throughout the year. Forms 300A and 300 are two of three OSHA forms required as part of the agency's recordkeeping rule. Learn more about the rule's requirements and whether you must comply, below. (Of course, all employers covered by the Occupational Safety and Health Act (the OSH Act) also must post a notice informing employees of the Act's protections and obligations. The notice must be posted in a conspicuous place or where notices to employees are customarily posted.) * General OSHA Recordkeeping Requirements * OSHA requires employers with 11 or more employees, except employers in certain low-hazard industries, to maintain a log and summary of all "recordable" occupational injuries and illnesses. An injury or illness is considered "recordable" if it meets the following three criteria:   1. It is work-related;   2. It is a new case; and   3. It results in death, days away from work, days of restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a diagnosis as "significant" by a physician or licensed health care professional. An occupational injury or illness is also recordable if it involves a needlestick or cut from a sharp object contaminated with another person's blood or other potentially infectious material, medical removal under an OSHA standard, certain occupational hearing loss (see below), or work-related tuberculosis. Employers in 56 low-hazard retail, service, finance, insurance, and real estate industries are exempt from this recordkeeping. These industries are specifically listed by Standard Industrial Classification (SIC) code in Appendix A of the OSHA recordkeeping regulations. Examples of the kinds of operations that are exempt include hardware stores, banks, physicians' offices, schools and colleges, and computer and data processing services. The regulations provide two forms for recording the required information, OSHA Forms 300 (the Log of Work-Related Injuries and Illnesses) and 300A (the Summary of Work-Related Injuries and Illnesses). You also must maintain a supplementary record for each recordable injury or illness on Form 301 (Injury and Illness Incident Report). Forms 300, 300A, and 301 should be maintained on a calendar year basis. * Form 300A: New Column for Hearing Loss * Form 300A is intended to summarize your yearly totals for illnesses and injuries and is taken from the information recorded on Form 300. It requires that you calculate the total number of deaths, cases with days away from work, cases with job transfers or restrictions, and any other recordable cases in a calendar year. In addition, you must identify the total number of days of job restrictions or transfers and days away from work. Finally, you must report what injuries and illnesses you experienced, including the total number of injuries, skin disorders, respiratory conditions, poisonings, hearing loss, and all other illnesses. Note that this is the first year employers have had to report work-related hearing loss in a special column on Form 300A. Changes to the OSHA recordkeeping regulations in 2002 required employers to collect this data on the Form 300 Log beginning January 1, 2004. * Where to Post Form 300A * You should post a copy of Form 300A, from February 1 until April 30, in each work establishment in a conspicuous place or places where notices to employees are customarily posted, such as in employee break areas or locker rooms. You also must ensure that the posted annual summary is not altered, defaced, or covered by other material. And finally, an executive must certify that the OSHA 300 Log has been examined and that the annual summary is believed to be correct and complete. The certifying executive can be either the owner or an officer of the organization, the highest-ranking executive at the establishment, or the supervisor of that highest-ranking executive. * Use Forms Issued in 2004 * OSHA revised the Forms 300 and 300A in late 2003, so you should be using the forms that say "Rev. 01/2004" to record all injuries that occurred beginning January 1, 2004. The forms are available online on OSHA's Web site at www.osha-slc.gov/recordkeeping/RKforms.html. OSHA also has posted a list of exempt industries online at www.osha- slc.gov/recordkeeping/ppt1/RK1exempttable.html.

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Subscribers to the Personnel Policy Manual and HR Policy Answers on CD can find more information on the OSHA's posting and recordkeeping requirements in Safety, Chapter 601, notes 19 and 20. Not a subscriber? If you would like to order the Safety chapter, go to: http://www.hrpolicyanswers.com.

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