The Occupational Safety and Health Administration (OSHA) requires that each year on February 1 employers covered by the Injury and Illness Recordkeeping Rules (29 C.F.R. §§ 1904.0 et seq.) post the official summary of all injuries and illnesses occurring in the previous year. The information must be compiled on the OSHA Form 300A or an equivalent and posted in a conspicuous place or places where notices to employees are customarily posted. The information must remain up through April 30, 2012.

Aside from the compliance obligation to ensure this posting, there are a number of reasons that employers should pay attention to this issue, not the least of which is that OSHA is continuing its National Emphasis Program (NEP) to inspect employer compliance with the recordkeeping obligations and issue citations and penalties where they are not met.

Review of Records

OSHA’s recordkeeping rules directly require each establishment to review its log of injuries and illnesses (the OSHA 300 Log) to verify that the entries are complete and accurate, and to correct any deficiencies identified. Prior to certification, the records must be reviewed as “extensively as necessary” to ensure their accuracy...

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