OSHA’s Requires Immediate Action by Certain Employers to Meet the February 1, 2013 Recordkeeping Deadline

Cole Schotz
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In keeping with OSHA’s injury and illness recordkeeping regulations, 29 C.F.R. 1904, on February 1, 2013 certain employers are required to post a summary of all injuries and illnesses that occurred in 2012.  Employers are required to use OSHA’s 300A summary form or equivalent thereof.  The summary must remain posted until April 30, 2013.  Even if there were no recordable incidents in 2012, companies are required to post the 300A summary form.

The summary form must be signed by a company executive and posted in a place where notices to employees are customarily posted or should be provided to employees who may not see the posted summary because they do not report to a fixed location on a regular basis.  The owner or officer of the company is required to certify the information contained in the OSHA 300A form.

OSHA’ recordkeeping requirements apply to all non-exempt employers.  Excluded from this regulation are companies with ten or fewer employees as well as low hazard industries such as retail, service industries, finance etc.  A full listing of exempt employers as well as OSHA’s recordkeeping forms and instructions can be found at its website http://www.osha.gov/.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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