Stay Ahead of OSHA Requirements

The start of a new year brings two important Occupational Safety and Health Administration (OSHA) record-keeping requirements that printing operations must be aware of and comply with, if they meet the thresholds. The requirements involve the completion, posting and submission of certain separate, but related, record-keeping forms.

Throughout the calendar year, OSHA requires companies with more than 10 full-, part-time or temporary employees to complete and maintain a Form 300 Log of Work-Related Injuries and Illnesses. This is to be completed for each work-related recordable injury and illness or fatality occurring in the workplace. For injuries, any incident resulting in medical treatment beyond first aid constitutes a recordable incident and must be entered in Form 300. OSHA has a specific list of first aid activities that needs to be examined prior to entering an injury.

All Form 300 entries are to be totaled at the end of each year, and the summary of the information is to be recorded in Form 300A (Summary of Work-Related Injuries & Illnesses). In addition to the summation of the workplace injuries and illnesses recorded during the previous calendar year, Form 300A must include the total hours worked that year by all employees covered by OSHA Form 300.

Once completed, Form 300A must be “certified” with the signature of a responsible company official, posted no later than February 1, and remain displayed through April 30. It must be posted in a conspicuous place(s), where employee notices are customarily posted.

Individuals who certify the 300A can be any of the following:

• owner of the company (only if the company is a sole proprietorship or partnership);
• officer of the corporation
• the highest ranking company official working at the establishment
• the immediate supervisor of the highest ranking company official working at the establishment

OSHA's second reporting requirement is that every printing operation that has, or had at any time last year, more than 20 full-, part-time or temporary employees must electronically submit their Form 300A data by March 2.

To allow employers to accept this data, OSHA created the Injury Tracking Application (ITA). The web-based form allows employers to electronically submit required injury and illness data from their completed 2019 OSHA Form 300A. The application is accessible at the ITA webpage.

The data submission process involves four steps:
1. Creating an establishment
2. Adding 300A summary data
3. Submitting data to OSHA
4. Reviewing the confirmation email

The secure website offers three options for data submission. One enables users to manually enter data into a web form, while another allows for uploading a CSV file to process single or multiple establishments simultaneously. The third option enables companies using automated record-keeping systems to transmit data electronically via an application programming interface.

A new requirement for the 2020 reporting year is providing your Employer Identification Number (EIN). This has been implemented so OSHA can better identify establishments, as company names can change over time.

Always keep copies of your electronic correspondence from OSHA to demonstrate that you have met the new reporting requirement.

In addition to these mandatory OSHA deadlines, don't forget to sign up for SGIA's 2020 Safety Recognition Program by January 31. SGIA's Government Affairs Department offers many resources, such as written program templates, to assist printing operations address their compliance programs. Please contact for assistance.