OSHA Update: Record keeping and required postings

Construction companies must remain vigilant in staying apprised of the Occupational Safety and Health Administration’s record keeping and notification requirements. Below are two issues that contractors need to be aware of moving forward.

Injury/illness summary for 2018 injuries must be posted from February 1 to April 30

Construction employers must post a copy of OSHA’s Form 300A from February 1 to April 30, 2019, which summarizes job-related injuries and illnesses logged during 2018. The summary must be displayed in a common area where notices to employees are usually posted. 

OSHA relieves contractors from some electronic record keeping

On January 24, OSHA published its final rule amending the record keeping regulation by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injuries and Illnesses Incident Report). These establishments will continue to submit information from their OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) as has been required in 2017 and 2018.

The final rule does not, however, alter an employer’s duty to maintain OSHA Forms 300 and 301 on-site. OSHA will continue to obtain these forms as needed through inspections and enforcement actions.

Businesses with 10 or fewer employees are exempt from OSHA record keeping and posting requirements. Visit OSHA’s Recordkeeping Rule webpage for more information on record keeping requirements.

If you have questions regarding your company’s OSHA obligations and compliance, contact one of the attorneys listed below.