EMPLOYERS MUST POST SUMMARY OF JOB RELATED INJURIES BY FEBRUARY 1
Covered employers must post a summary of job-related injuries and illnesses from 2009 at their place of business by February 1. In particular, the California Department of Industrial Relations (DIR) requires the Cal/OSHA Log 300A summary be displayed from February 1 to April 30 for employee review. Companies that had 10 or fewer employees at all times during the last calendar year, do not need to keep Cal/OSHA injury and illness records, and as a result, do not need to post a summary of job-related injuries.
However, employers with 11 or more employees, except those covered in the California low-hazard establishments in the retail, service, finance and real estate sectors, must display the totals from the Summary of Work-Related Injuries and Illnesses (CAL/OSHA Form 300A) wherever employee notices are usually posted. If there is more than one business establishment, a separate log and summary must be posted in each physical location that is expected to be in operation for one year or longer.
The summary form (Form 300A) must be completed and posted beginning February 1. This form contains a summary of the total number of job-related injuries and illnesses that occurred during the previous year. Employers are required to post only the summary (Form 300A)-not the Form 300 (Log)-from February 1 to April 30. Employers must not post Form 300 because this form contains sensitive and/or confidential information about employees.
The summary must list the total number of job-related injuries and illnesses that occurred in the previous year and were logged on the Form 300 (Log). Companies with no recordable injuries or illnesses in the previous year must post the summary with zeros on the "total" line. A company executive must certify all establishment summaries.
The form is to be displayed in a common area where notices to employees usually are posted. Employers must also make a copy of the summary available to employees who move from worksite to worksite, such as construction workers, and employees who do not report to any fixed establishment on a regular basis.
Those employers who are exempt from the recordkeeping or posting requirements must still continue to file reports of occupational injuries and illnesses with the state Division of Labor Statistics and Research.
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Richard S. Rosenberg Partner BRG&S, LLP
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