Section 1904.32Annual summary(66 FR 6131, Jan. 19, 2001)REGULATION: Section 1904.32Subpart D – Other <strong>OSHA</strong> injury and illness recordkeeping requirements(66 FR 6130, Jan. 19, 2001)§1904.32(a) Basic requirement.At the end of each calendar year, you must:(1) Review the <strong>OSHA</strong> 300 Log to verify that theentries are complete and accurate, and correct anydeficiencies identified;(2) Create an annual summary of injuries and illnessesrecorded on the <strong>OSHA</strong> 300 Log;(3) Certify the summary; and(4) Post the annual summary.(b) Implementation.(1) How extensively do I have to review the<strong>OSHA</strong> 300 Log entries at the end of the year?You must review the entries as extensively as necessaryto make sure that they are complete and correct.(2) How do I complete the annual summary?You must:(i) Total the columns on the <strong>OSHA</strong> 300 Log (if youhad no recordable cases, enter zeros for each columntotal); and(ii) Enter the calendar year covered, the company’sname, establishment name, establishmentaddress, annual average number of employeescovered by the <strong>OSHA</strong> 300 Log, and the total hoursworked by all employees covered by the <strong>OSHA</strong>300 Log.(iii) If you are using an equivalent form other thanthe <strong>OSHA</strong> 300-A summary form, as permittedunder Section 1904.6(b)(4), the summary you usemust also include the employee access andemployer penalty statements found on the <strong>OSHA</strong>300-A Summary form.(3) How do I certify the annual summary?A company executive must certify that he or shehas examined the <strong>OSHA</strong> 300 Log and that he or shereasonably believes, based on his or her knowledgeof the process by which the information was recorded,that the annual summary is correct and complete.(4) Who is considered a company executive?The company executive who certifies the log mustbe one of the following persons:(i) An owner of the company (only if the companyis a sole proprietorship or partnership);(ii) An officer of the corporation;(iii) The highest ranking company official workingat the establishment; or(iv) The immediate supervisor of the highest rankingcompany official working at the establishment.(5) How do I post the annual summary?You must post a copy of the annual summary ineach establishment in a conspicuous place or placeswhere notices to employees are customarily posted.You must ensure that the posted annual summary isnot altered, defaced or covered by other material.(6) When do I have to post the annual summary?You must post the summary no later than February1 of the year following the year covered by therecords and keep the posting in place until April 30.PREAMBLE DISCUSSION: Section 1904.32(66 FR 6042-6048, Jan. 19, 2001)The following are selected excerpts from the preamble to the Occupational Injury and Illness Recording andReporting Requirements, the <strong>Recordkeeping</strong> rule (66 FR 5916, 29 CFR Parts 1904 and 1952). These excerptsrepresent some of the key discussions related to the final rule (66 FR 6122, 29 CFR Parts 1904 and 1952).Section 1904.32 Annual summary.At the end of each calendar year, section 1904.32 ofthe final rule requires each covered employer toreview his or her <strong>OSHA</strong> 300 Log for completenessand accuracy and to prepare an Annual Summary ofthe <strong>OSHA</strong> 300 Log using the form <strong>OSHA</strong> 300-A,Summary of Work-Related Injuries and Illnesses, oran equivalent form. The summary must be certifiedfor accuracy and completeness and be posted in theworkplace by February 1 of the year following the134<strong>OSHA</strong> RECORDKEEPINGHANDBOOK
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 <strong>OSHA</strong> 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 <strong>OSHA</strong>300 Log. If a form other than the <strong>OSHA</strong> 300-A isused, as permitted by paragraph 1904.29(b)(4), thealternate form must contain the same information asthe <strong>OSHA</strong> 300-A form and include identical statementsconcerning employee access to the Log andSummary and employer penalties for falsifying thedocument as are found on the <strong>OSHA</strong> 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 <strong>OSHA</strong>records) 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 <strong>OSHA</strong> 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. <strong>OSHA</strong> concludesthat the company executive certificationprocess will ensure greater completeness and accuracyof the Summary by raising accountability for<strong>OSHA</strong> recordkeeping to a higher managerial levelthan existed under the former rule. <strong>OSHA</strong> believesthat senior management accountability is essential ifthe Log and Annual Summary are to be accurate andcomplete. The integrity of the <strong>OSHA</strong> recordkeepingsystem, which is relied on by the BLS for nationalinjury and illness statistics, by <strong>OSHA</strong> 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 <strong>OSHA</strong> 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).§1904.32<strong>OSHA</strong> RECORDKEEPINGHANDBOOK135
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OSHARecordkeeping HandbookThe Regul
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Section 1904.40Providing records to
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§1904.0…OSHA has rejected the su
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§1904.1Since publication of the re
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§1904.2SIC code Industry descripti
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Section 1904.3Keeping records for m
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PREAMBLE DISCUSSION: Section 1904.4
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(viii)(ix)The illness is the common
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§1904.5employment environment. For
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§1904.5the employee’s status as
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§1904.5Exceptions Proposed but Not
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§1904.5pain and swelling in a join
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§1904.5the worker has taken a side
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§1904.526“Personal tasks” for
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If the accident had occurred in a l
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Scenario 4:• An employee reports
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In applying [the presumption of wor
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Letters of interpretation related t
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November 19, 2002Joseph Woodward, E
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Letter of interpretation related to
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§1904.6that the two injuries or il
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§1904.6…Under the OSHA recordkee
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FREQUENTLY ASKED QUESTIONS: Section
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Since the employee was not performi
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In each of the eight scenarios in y
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§1904.7other licensed health care
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§1904.7that eliminates the routine
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§1904.7pose. This paragraph also s
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§1904.7Counting Lost Workdays When
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§1904.7tors to such injuries and i
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§1904.7This list of first aid trea
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§1904.7visit to a health care prof
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§1904.7However, as discussed above
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§1904.766immediate recording of si
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§1904.7strength? How is an employe
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§1904.7or illness. The severity of
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The first treatment is glue used to
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Response: The employer would have t
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Letter of interpretation related to
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Letter of interpretation related to
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§1904.8exposure” as these terms
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ing blood and other potentially inf
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allows him or her to independently
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§1904.46the three criteria above,
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§1904.46approach will provide an i
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FREQUENTLY ASKED QUESTIONS: Section
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Section 1952.4Injury and illness re