OSHA’s Recordkeeping Standard, 29 CFR 1904, requires that certain employers maintain annual records of workplace injuries and illnesses. The records are maintained throughout the calendar year on the OSHA Form 300 Log of Work-Related Injuries and Illnesses (300 Log) and are summarized on the OSHA Form 300A Summary of Work-Related Injuries and Illnesses (300A Summary) at the end of each calendar year. The 300A Summary is required to be posted in the workplace every Feb. 1 through April 30 to show records from the previous year’s injuries and illnesses, even if no work-related injuries or illnesses occurred during the previous year.
Helping your company comply with OSHA regulations is one of the key benefits of ADP TotalSource®. If your company is not partially exempt (either by industry, size, or both) from OSHA recordkeeping requirements, ADP will help you fulfill this responsibility by providing your company with its preliminary 300 Log and 300A Summary at the end of January each year. The preliminary 300 Log and 300A Summary are available through your MyTotalSource® website. Please see access instructions below.
As the worksite employer, you may need to take additional steps to ensure your 300 Log and 300A Summary fully capture the information required by OSHA. The preliminary 300 Log and 300A Summary are based on workers’ compensation data reported to TotalSource and may not contain all the information necessary to complete the 300 Log and 300A Summary. The preliminary 300 Log, for example, may be missing adequate details describing the injury or cause of injury because that information was not provided when the injury or illness was reported.
Additionally, since workers’ compensation and OSHA recordable injuries are not directly correlated, there may have been injuries at your workplace that were not reported to workers’ compensation or denied by workers’ compensation that should be included on your 300 Log and 300A Summary. For example, OSHA requires that controlling worksite employers record data for injuries and illnesses for temporary employees and sub-contracted employees used by those employers. TotalSource does not have access to temporary and/or sub-contracted employee injury and illness data and, as such, it will not be included on your preliminary 300 Log and 300A Summary.
Recording workplace exposures to COVID-19
COVID-19 can be a recordable illness if a worker is infected by performing his/her work-related duties. However, employers are only responsible for recording cases of COVID-19 if all the following are true:
- The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19).
- The case is work-related (as defined by 29 CFR 1904.5); and
- The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).
Employers should follow the OSHA enforcement guidance found in the Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19).
PureSafety course available on myLearning@ADP
The course “OSHA 300 Recordkeeping Requirements” is available on-demand through ADP’s learning management system, myLearning@ADP for free! . Access to myLearning@ADP is through your MyTotalSource website.
Questions
If you have any questions about the information on your preliminary OSHA 300 Log or 300A Summary and/or would like additional guidance on OSHA recordkeeping requirements, such as partial exemptions, please contact your TotalSource Risk and Safety Consultant for assistance.
How to access preliminary OSHA 300 Log and OSHA 300A Summary in MyTotalSource
1. Enter your paygroup and click ‘GO’
2. Click on the ‘Workers Comp’ tab
3. Click on ‘300A (OSHA Summary)’ and/or ‘OSHA 300 Log’
4. Enter ‘2021’ for the year
5. Click ‘Get’ and review reports
6. Print and sign both reports
7. Post OSHA 300A Summary
