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OSHA Form 300A Postings and Revised Injury Reporting Requirements

Labor & Employment Law Alert Fred Gants, Lauren R. Harpke, Janine M. Landow-Esser

Along with the fading of Auld Lang Syne and sweeping up the New Year’s Eve confetti, the new year of 2015 brings with it the standard annual requirement to post the Occupational Safety and Health Act (“OSHA”) Form 300A injury and illness summary logs. The year 2015 also brings us certain changes to the OSHA reporting requirements for major injuries and illnesses going forward.

If your facility was subject to Form 300 injury and illness reporting requirements in 2014, then your facility is also required, at the beginning of 2015, to post OSHA Form 300A summarizing the previous year’s job-related injuries and illnesses. The forms must remain posted from February 1 through April 30 and should be located in a conspicuous place or places where notices to employees are usually placed. Employees, former employees and their representatives also have a right to review the OSHA Form 300 in its entirety.

Additionally, effective January 1, 2015, two major changes went into effect related to required reporting for workplace injuries and illnesses.

First, OSHA revised the list of industries exempt from the reporting rule due to typically low rates of workplace injuries and illnesses in those industries. The newly revised rule lists the exempt industries by referencing the NAICS Codes of industries with comparably low injury rates based on data from recent years. By comparison, the previous rule referenced the old SIC codes and used data on injury rates from earlier years that is now outdated. As a result, in 2015, a facility should reevaluate the OSHA recordkeeping and reporting rule’s applicability provisions and exemptions to determine whether it is an employer that is now required to report injuries and illnesses. However, regardless of the industry-specific NAICS code applicability determination, the revised OSHA rule retains the previous reporting exemption for employers who have fewer than ten employees.

Second, the revised OSHA rule modified the types of injuries and illnesses that will require reporting to the Agency. Although the newly revised OSHA rule retains the requirement to report workplace related fatalities within eight hours, it also adds the requirement to report work-related inpatient hospitalizations, amputations or losses of an eye within 24 hours. Therefore, facility health and safety policies should be updated to include a requirement to report and record these new categories of injuries and illnesses.

For more information, or assistance in evaluating the new OSHA injury reporting requirements, please contact any of the following: Fred Gants at (608) 283-2618 / [email protected], Lauren Grahovac Harpke at (414) 277-5183 / [email protected], Janine M. Landow-Esser at (312) 715-5055 / [email protected], or your Quarles & Brady attorney.

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