Reminder to Post OSHA 300A – Annual Summary of Work-Related Injuries and Illnesses

Many trucking companies have a misconception that OSHA regulations do not apply to their operations – at all.  While it is true that DOT regulations are the pervasive concern to many trucking company safety directors, they must remember that trucking companies are still employers, and there’s plenty of OSHA regulations that apply to them.  One particular OSHA standard that applies to virtually all types of organizations (even construction, maritime, etc.) is the recordkeeping [sic] standard -29 CFR § 1904.

The previous paragraph comes as no surprise to many trucking companies, but to some it’s an epiphany. No matter which of those situations describe your company, you will still appreciate friendly reminders.  Therefore, keep in mind that it’s that time of year again for employers to be completing and posting the OSHA 300A, Annual Summary of Work-Related Injuries and Illnesses, for the calendar year of 2009.  This form, or an appropriate equivalent, should be posted in a conspicuous location at each establishment beginning February 1st and remaining through April 30th.  This requirement covers many employers in the U.S., however there are some exceptions.  Organizations with 10 or fewer employees, or those that have a particular industrial classification (i.e., insurance agencies, real estate agencies, car dealerships, etc.) are considered partially exempt from OSHA’s recordkeeping [sic] standards, and are not required to keep the forms unless OSHA has specifically told them, in writing, that they must.   Unfortunately the common, trucking standard industrial classification codes, 4212, 4213, 4214, 4226, 4213 and 4289, are NOT on this list.  A list of the partially exempt industries can be found at the following site:  Standard Industrial Classification Codes for Partially Exempt Industries. 

The process and regulatory requirements for completing the 300A are outlined in OSHA’s Standard on Recordkeeping [sic]; specifically at 29 CFR § 1904.32 .   Access to OSHA Recordkeeping [sic] forms can be found at OSHA Recordkeeping Forms .

Keep in mind, if you organization is not partially exempt, you are required to post the 300A even if there were no OSHA recordable injuries for 2009.  OSHA still wants the zeros posted!

So, if you have more than 10 employees and your business is not listed as one of the partially exempt industrial classifications, you need to get your OSHA 300 log completed, totaled and the necessary information transferred to the 300A.  If you’re not partially exempt, and you don’t know what an OSHA 300 log is, then you’ve got some work to do.