OSHA Recordkeeping Handbook - Msabc.net

year covered by the summary. The summary mustremain posted until April 30 of the year in which itwas posted.Preparing the Annual Summary requires foursteps: reviewing the OSHA 300 log, computing andentering the summary information on the Form 300-A, certification, and posting. First, the employer mustreview the Log as extensively as necessary to makesure it is accurate and complete. Second, theemployer must total the columns on the Log; transferthem to the summary form; and enter the calendaryear covered, the name of the employer, the nameand address of the establishment, the average numberof employees on the establishment’s payroll forthe calendar year, and the total hours worked by thecovered employees. If there were no recordablecases at the establishment for the year covered, thesummary must nevertheless be completed by enteringzeros in the total for each column of the OSHA300 Log. If a form other than the OSHA 300-A isused, as permitted by paragraph 1904.29(b)(4), thealternate form must contain the same information asthe OSHA 300-A form and include identical statementsconcerning employee access to the Log andSummary and employer penalties for falsifying thedocument as are found on the OSHA 300-A form.Third, the employer must certify to the accuracyand completeness of the Log and Summary, using atwo-step process. The person or persons who supervisethe preparation and maintenance of the Log andSummary (usually the person who keeps the OSHArecords) must sign the certification statement on theform, based on their direct knowledge of the data onwhich it was based. Then, to ensure greater awarenessand accountability of the recordkeepingprocess, a company executive, who may be anowner, a corporate officer, the highest ranking officialworking at the establishment, or that person’s immediatesupervisor, must also sign the form to certify toits accuracy and completeness. Certification of thesummary attests that the individual making the certificationhas a reasonable belief, derived from his orher knowledge of the process by which the informationin the Log was reported and recorded, that theLog and summary are “true” and “complete.”Fourth, the Summary must be posted no laterthan February 1 of the year following the year coveredin the Summary and remain posted until April30 of that year in a conspicuous place where noticesare customarily posted. The employer must ensurethat the Summary is not defaced or altered duringthe 3 month posting period.Changes from the former rule.Although the final rule’s requirements for preparingthe Annual Summary are generally similar to thoseof the former rule, the final rule incorporates fourimportant changes that OSHA believes will strengthenthe recordkeeping process by ensuring greatercompleteness and accuracy of the Log andSummary, providing employers and employees withbetter information to understand and evaluate theinjury and illness data on the Annual Summary, andfacilitating greater employer and employee awarenessof the recordkeeping process.1. Company Executive Certification of the AnnualSummary.The final rule carries forward the proposed rule’srequirement for certification by a higher rankingcompany official, with minor revision. OSHA concludesthat the company executive certificationprocess will ensure greater completeness and accuracyof the Summary by raising accountability forOSHA recordkeeping to a higher managerial levelthan existed under the former rule. OSHA believesthat senior management accountability is essential ifthe Log and Annual Summary are to be accurate andcomplete. The integrity of the OSHA recordkeepingsystem, which is relied on by the BLS for nationalinjury and illness statistics, by OSHA and employersto understand hazards in the workplaces, by employeesto assist in the identification and control of thehazards identified, and by safety and health professionalseverywhere to analyze trends, identify emerginghazards, and develop solutions, is essential tothese objectives. Because OSHA cannot oversee thepreparation of the Log and Summary at each establishmentand cannot audit more than a small sampleof all covered employers’ records, this goal is accomplishedby requiring employers or company executivesto certify the accuracy and completeness of theLog and Summary.The company executive certification requirementimposes different obligations depending on the structureof the company. If the company is a sole proprietorshipor partnership, the certification may bemade by the owner. If the company is a corporation,the certification may be made by a corporate officer.For any management structure, the certification maybe made by the highest ranking company officialworking at the establishment covered by the Log (forexample, the plant manager or site supervisor), orthe latter official’s supervisor (for example, a corporateor regional director who works at a differentestablishment, such as company headquarters).§1904.32OSHA RECORDKEEPINGHANDBOOK135