The annual requirement for employers to post copies of their OSHA Form 300A rolls around again this week. On February 1, 2023, employers subject to the Occupational Safety and Health Administration's recordkeeping requirements must post their Form 300A's, otherwise known as the "Summary of Work-Related Injuries and Illnesses."

Each year, most employers having 10 or more employees are required to complete the OSHA Form 300A which summarizes the work-related injuries and illness that its employees experienced during the previous calendar year. Covered employers must complete and post the form by February 1, 2023, even if there are no injuries or illnesses recorded for the prior year. Minor injuries that only required first aid treatment need not be included. The notices must be posted within each establishment in conspicuous places where employees typically view posted notices, and employers must ensure that the posted annual summary is not altered, damaged or covered by subsequent notices. The Form 300A must be completed and certified by the highest-ranking company executive (or that executive's supervisor) working at the applicable work location as correct and complete and must remain posted from February 1, 2023 until April 30, 2023.

Consistent with previous years, OSHA penalties have been adjusted for inflation. This year, the Department of Labor (DOL) announced that penalties increased sharply by 7.75%, effective January 15, 2023, for any penalty that is assessed after the 15th. This increase applies to any penalty imposed by the DOL including OSHA Form 300A violations. Employers should ensure that their complete and accurate summaries are certified and posted from February 1, 2023 until April 30, 2023.

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