Annual Summary of Workplace Injuries: Frequently Asked Questions

The Log of Work-Related Injuries and Illnesses (Log) is a federal form required by the Occupational Safety and Health Administration (OSHA) and used by employers to classify work-related injuries and illnesses. OSHA also requires employers to complete an Incident Report for each recordable injury and illness. At the end of each calendar year, each covered employer must review their Log for completeness and accuracy and prepare a summary of the Log using the form OSHA 300-A (Annual Summary). The Annual Summary must then be posted in the workplace for a certain period each year.

To help employers understand this requirement, here are the answers to frequently asked questions about the Annual Summary. Note: The answers to the following questions are based on federal rules. There are currently 22 states with their own rules for workplace safety in the private sector. These are known as state-plan states and they may have requirements that are greater than the federal rules. If you operate in a state-plan state, check your state rules for details.

Q: When and where must the Annual Summary be posted in the workplace?

A: Covered employers must post the Annual Summary for the previous year no later than February 1 and display it until April 30 each year. The Annual Summary must be posted in each establishment in a conspicuous place or places where notices to employees are customarily displayed.

Q: Who is covered by the Annual Summary requirement?

A: Many employers are covered. However, employers with 10 or fewer employees throughout the previous calendar year are exempt from completing the Annual Summary (as well as the Log and Incident Report). This is known as the small employer exemption.

When counting employees for this exemption, you must include full‐time, part‐time, temporary, and seasonal workers. This exemption is based on the employment of the entire company rather than the establishment. For example, if a company has two establishments, one with five employees and one with seven employees, the company must fill out the forms for each establishment because the company employment is greater than 10 employees.

In addition to the small employer exemption, there is an exemption for establishments classified in certain lower-hazard industries, such as restaurants and medical offices. A complete list of exempt industries can be found on this OSHA web page.

Establishments normally exempt from completing the forms must complete them if they are informed in writing to do so by the Bureau of Labor Statistics or OSHA.

Q: If I’m a covered employer, do I also have to submit the Annual Summary to OSHA?

A: Hard copies of the forms shouldn’t be sent to OSHA. However, many employers are required to electronically submit information from their Annual Summary to OSHA each year by March 2. An establishment must do so if it meets one of the following criteria:

It has 250 or more employees and isn’t in an industry listed in the Exempt Industries list in Appendix A to Subpart B of OSHA's recordkeeping regulation of 29 CFR Part 1904; or
It has 20 to 249 employees and is in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904.

Keep in mind that the reporting criteria for this rule are based on the size and industry of each individual establishment, not the company as a whole. For example, if a company has two manufacturing establishments, one with 17 employees and one with 25 employees, the company only needs to submit electronically Annual Summary data for the establishment with 25 employees. While manufacturing is a covered industry, establishments with fewer than 20 employees aren’t required to submit their Annual Summary.

Note: Establishments with 100 or more employees and in designated industries listed in Appendix B to Subpart E of 29 CFR Part 1904 are also required to submit the Log and Incident Reports to OSHA electronically each year.

Q: How do I complete the Annual Summary?

Total the columns on the Log (if you had no recordable cases, enter zeros for each column total); and
Enter the calendar year covered, the company's name, establishment name, establishment address, annual average number of employees covered by the Log, and the total hours worked by all employees covered by the Log.

A company executive must certify that they have examined the OSHA 300 Log and that they reasonably believe, based on their knowledge of the process by which the information was recorded, that the Annual Summary is correct and complete.

More information can be found here.

Q: An employee asked to see a copy of the Annual Summary from 2022. Do I have to let them see it?

A: Employers must keep the Annual Summary (as well as Logs and Incident Reports) on file for five years following the year to which they pertain. The forms must be made available to employees, former employees, their representatives, and to OSHA officials upon request.

Conclusion

Make sure you understand and comply with the safety recordkeeping rules that apply to your business (consider state, local and industry requirements as well).