Last year, Cal/OSHA implemented new injury and illness recording rules to be phased in over five years. The new rules updated the requirements for posting, retaining and reporting work-related injuries and illnesses. Many of the key changes are taking effect in 2003—including the injury and illness information that must be posted starting in February. We’ll go over what you need to do to meet the new requirements.
New Forms to Use
Cal/OSHA has discontinued the use of its former recordkeeping forms, including the old Form 200, but you must retain your previous records under the old rule for five years.
The new Form 300 log of work-related injuries and illnesses requires employers to classify each work-related injury or illness and to note the extent and severity of each case. If the incident caused the employee to miss work or restricted the work the employee could complete, employers must include the number of calendar days involved. However, in a change from the old rules, you may now stop counting the days of restricted work activity or days away from work when the total days of either, or of both, reaches 180.
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Posting New Summary Report
In another change, employers must now post the Form 300A annual summary log of injuries and illnesses that occurred in the previous year rather than the old Form 200A. Here’s how to meet your posting obligations:
- Review your Form 300 log. Make sure it’s accurate and complete for all the previous year’s injuries and illnesses. Also, never post the actual log, only the summary report (see below).
- Create a Form 300A summary report. Transfer the total number of cases, days lost, and injury and illness types from the previous year’s Form 300 log. You must complete the Form 300A summary even if no injuries or illnesses occurred in the previous year.
- Certify the summary. A company executive must certify that the summary is complete and correct based on their examination of the Form 300 log and reasonable belief based on their knowledge of your company’s recording process.
- Post the certified Form 300A summary from February 1 to April 30. You must display the summary somewhere conspicuous where you normally post notices to employees. Note that under the old rules, you only had to post the summary for the month of February each year. Beginning this year, it must remain up from February 1 through April 30. During the posting period, you’re responsible for making sure employees don’t deface or remove the summary or cover it with other documents.
For More Information
Cal/OSHA has prepared a helpful guide to complying with the new recordkeeping and posting requirements.