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Compliance & programs
Every February 1, covered employers must post their Form 300A injury summary — and many must e-file it by March 2. Who's covered, the most common errors, and the checklist that keeps January calm.
Key takeaway: Covered employers must post their completed OSHA Form 300A — the annual summary of work-related injuries and illnesses — in a visible workplace location from February 1 through April 30, covering the prior calendar year. Many establishments must also electronically submit their data to OSHA by March 2, with submission scope depending on establishment size and industry. The summary must be certified by a company executive — and “we had no recordables” doesn’t exempt you: a zero-injury 300A still gets posted. [COMPLIANCE VERIFY all dates and thresholds against current rules before publish]
This checklist is for Colorado employers handling OSHA recordkeeping without a dedicated compliance department.
Employers with more than 10 employees at any point in the year must keep OSHA injury and illness records (Forms 300, 300A, 301) unless their industry is on OSHA’s low-hazard exempt list. Even exempt and small employers must still report severe incidents directly to OSHA: fatalities within 8 hours; in-patient hospitalizations, amputations, or eye losses within 24 hours — that obligation has no size exemption. [COMPLIANCE VERIFY]
Electronic submission adds a second layer: establishments at certain size thresholds, and those in designated higher-hazard industries, must e-file 300A data through OSHA’s Injury Tracking Application by March 2 — and the largest establishments in designated industries submit detailed 300/301 data as well. The thresholds have changed in recent years; check your establishment against the current rule rather than memory. [COMPLIANCE VERIFY current thresholds]
A work-related injury or illness is recordable when it involves death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or significant diagnosed injury/illness. The chronic gray zone is the first-aid boundary — OSHA defines first aid as a specific list (cleaning minor wounds, bandages, non-prescription medication at non-prescription strength, and so on), and treatment outside that list is recordable regardless of how minor it felt. This is where clinic documentation quality matters: precise treatment records make recordability determinations defensible instead of debatable. [LINK: occupational health vs. urgent care]
| When | Task |
|---|---|
| Early January | Reconcile the year’s 300 log against claims files and clinic records — find the strain that never got logged |
| Mid January | Verify day counts: days away and restricted-duty days, counted by calendar days per OSHA’s method |
| Mid January | Calculate average employment and total hours worked for the 300A (payroll has this) |
| Late January | Company executive certifies the 300A — required signature, not a delegated formality |
| February 1 | Post in the location where employee notices go; multi-establishment employers post per establishment |
| By March 2 | E-file via the Injury Tracking Application if your establishment meets the criteria |
| April 30 | Posting may come down; retain records five years |
ICA’s injury documentation is built for exactly this: clear treatment records that make first-aid vs. recordable determinations clean, work-status reports that make day counts accurate, and a January-friendly paper trail. Employers: bring your 300 log questions when we review your year — and if injury frequency is the real problem behind the paperwork, that’s a [LINK: prevention program] conversation. [LINK: Employer Resources]
Is the 300A the same as reporting injuries to OSHA? No — three separate duties: maintain the log (300/300A/301), post the 300A each February–April, and e-file if covered. Severe-incident reporting (the 8/24-hour calls) is a fourth, separate, immediate obligation.
Do workers’ comp claims and recordables always match? No — the definitions differ. Some comp claims aren’t recordable and some recordables never become claims. Reconcile the lists; don’t assume either one is the other.
Who counts as a “company executive” for certification? An owner, officer, or the highest-ranking official working at the establishment (or their immediate supervisor) — per OSHA’s specific list. [COMPLIANCE VERIFY]
General information, not legal advice. OSHA’s recordkeeping rules and your industry classification govern specifics.
[Medically reviewed by — REQUIRED] · Last reviewed: [DATE]
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