Reminder: Iowa OSHA Form 300A Posting Requirements

The February 1, 2013 date for posting the Iowa OSHA Form 300A is almost here. If you have not done so already, it's time to create an annual summary of injuries and illnesses recorded on your Iowa OSHA 300 Log. Be sure to review your Iowa OSHA 300 Log entries as extensively as necessary to make sure they are complete and accurate, and correct any deficiencies.

Completing the Form 300A:

To complete the Form 300A Summary of Work-Related Injuries and Illnesses, total the columns on the OSHA 300 Log, enter the company's name, establishment name and address, annual average number of employees covered by the OSHA 300 Log, and the total hours worked by all employees covered by the OSHA 300 Log. The form is available for downloading from federal OSHA at http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf and http://www.osha.gov/recordkeeping/new-osha300form1-1-04.xls. Note that the form must be posted even if there are no 'reportable' injuries!

Certification of the Form 300A:

The Form 300A must be certified by a 'company executive,' which means:

• 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 a the establishment; or
• the immediate supervisor of the highest ranking company official working at the establishment.

By certifying the Form 300A, the company executive represents that he or she has examined the OSHA 300 Log and reasonably believes, based on the executive's knowledge of the process by which the information was recorded, that the annual summary is correct and complete.

Posting and Maintenance Requirements:

The Form 300A must be posted in each establishment, in a conspicuous place or places where notices to employees are customarily posted, no later than February 1, 2013 and kept in place until April 30, 2013. An employer must also ensure that the posted annual summary is not altered, defaced or covered by other material. Employers must maintain the OSHA 300 Log, the privacy case list (if one exists), the 300A Summary and the OSHA 301 Incident Report forms for five years following the end of the calendar year that the records cover. The employer need not send any recordkeeping forms to IOSHA or any other agency unless requested.

Exempt Employers:

An employer with ten or fewer employees is exempt from maintaining the OSHA log of injuries and illnesses, unless the Bureau of Labor Statistics or IOSHA notifies them that they have been selected to participate in mandatory data collection. Iowa OSHA also exempts establishments in certain low-hazard industries from most of the record-keeping requirements. 29 CFR § 1904.2. That exemption is identified by SIC code, and includes those classified as '60 Depository Institutions (Banks and Savings Institutions)' and '81 Legal Services.'  A listing of the SIC classifications that are covered by the exemption (as of December 1, 2012) is available here or here. Please note that exempt employers must still comply with requirements to display an Iowa OSHA Safety and Health poster and to report to IOSHA within eight hours any accident that results in one or more fatality or the hospitalization of three or more employees.