The Occupational Safety and Health Administration (OSHA) will be enforcing its new reporting requirements that became effective on January 1, 2015. Employers are now required to contact OSHA within 24 hours following an occurrence of any in-patient hospitalizations, amputations, or loss of an eye. The requirement to contact OSHA within eight (8) hours following a fatality has not changed. Employers have three (3) options when contacting OSHA: 1) call the nearest area office; 2) call OSHA’s 24-hour hotline 1-800-321-OSHA; or 3) report online.
OSHA has also added 25 new categories of employers who must now maintain and post OSHA injury and illness records going forward. Previously exempt employers should go to OSHA’s website to review the updated list to see if they are now required to comply with the rules. Employers who were already covered must complete and post their 2014 summary by February 1, 2015.
Employers must utilize the annual summary form (form 300A) to comply with the posting requirements. The recordkeeping rules require employers to review the form to ensure accuracy, as even minor errors in descriptions can be scrutinized. The 300A summary must be completed and certified by a company executive as defined by OSHA rules. Please note that human resources managers and safety directors normally cannot sign the OSHA 300A summary unless they are officers of the company. Even where an employer has had no recordable injuries or illnesses, you must still post a certified 300A summary with zeros in the appropriate lines.
The 300A summary must be posted in each establishment in a conspicuous place or places where notices to employees are customarily posted. If your company has employees who work from home or at another location, you should provide them with a copy. The annual signed poster should be retained for record keeping purposes.
If you have any questions regarding OSHA requirements, please contact any of the attorneys at Royal LLP at (413) 586-2288.