It’s that time of year again: Beginning February 1, 2022, California employers must post their Form 300A, Annual Summary of Work-Related Injuries and Illnesses (which includes COVID-19-related injuries) in a visible and easily accessible area at every worksite. The Form 300A summary must remain posted through April 30.
This year, the Form 300A will summarize all job-related injuries and illnesses from 2021 that were logged on Form 300, Log of Work-Related Injuries and Illnesses. As for COVID-19 occurrences in the workplace, if the incident results in the same conditions as any other occupational illness, it must be recorded on Forms 300, 300a and 301 — the California Division of Occupational Safety and Health’s (Cal/OSHA) has provided guidelines specifically for reporting COVID-19 workplace occurrences.
Cal/OSHA’s Record Keeping Overview offers form templates and instructions on completing both the log (Form 300) and annual summary (Form 300A) of work-related injuries and illnesses. To be recordable, an illness must be work-related and result in:
- Death;
- Days away from work;
- Restricted work or transfer to another job;
- Medical treatment beyond first aid;
- Loss of consciousness; or
- A significant injury or illness diagnosed by a physician or other licensed health care professional.
Companies with no recordable injuries or illnesses in 2021 still must post the summary with zeros on the “total” line.
Posting the summary helps ensure workers are aware of work-related injuries and illnesses that occurred the previous year. Current and former employees and their representatives are entitled to a copy of the summary or the log upon request.
Remember, employers must post only the summary (Form 300A), not the log (Form 300), and an owner, corporate officer, highest-ranking person at the establishment or immediate supervisor of the highest-ranking person at the establishment must certify the annual summary.
In addition to posting the Form 300a in a visible and easily accessible area of their business where employee notices typically are displayed, employers also must make a copy of Form 300A available to employees who don’t regularly report to a fixed establishment. Current and former employees also are entitled to a copy of either form upon request.
Neither Cal/OSHA nor the federal Occupational Safety and Health Administration (OSHA) have posted any updated guidance for employers about posting the Form 300a during the COVID-19 pandemic when many workplaces are remote.
Electronic Reporting Due March 2
Cal/OSHA also requires certain California employers to electronically submit Form 300A data to the federal OSHA. Employers must electronically report their 2021 Form 300A by March 2, 2022, if they:
- Employ 250 or more workers, unless specifically exempted by California Code of Regulations Title 8, Section 14300.2.
- Employ 20 to 249 workers in the industries listed in Appendix H of Cal/OSHA’s related regulations.
Electronic reporting doesn’t change the requirement that all employers keep and maintain Form 300, Form 300A and Form 301 for five years, regardless of their size.
HRWatchdog
CalChamber members can use the Log 300 Wizard to help get information their company needs to be complaint with complex Log 300 requirements. They can also find more information on filing and posting requirements from Recording Work-Related Injuries and Illnesses in the HR Library. Not a member? Learn about the benefits of a membership.
