Katie Culliton  January 26, 2021 137

Even during the COVID-19 pandemic, some things remain the same. California employers must still post their Form 300A, Annual Summary of Work-Related Injuries and Illnesses, on February 1, 2021, and keep it posted through April 30, 2021.

Form 300A summarizes all job-related injuries and illnesses from the previous calendar year that were logged on Form 300, Log of Work-Related Injuries and Illnesses. Remember, the California Division of Occupational Safety and Health (Cal/OSHA) has provided guidelines for reporting occurrences of COVID-19 in the workplace. If a COVID-19 incident results in the same conditions as any other occupational illness, then it must be recorded on the Forms 300, 300a and 301.

Employers must post only the summary (Form 300A), not the log (Form 300). An owner, corporate officer, highest-ranking person at the establishment or immediate supervisor of the highest-ranking person at the establishment must certify the annual summary.

Companies with no recordable injuries or illnesses in 2020 still must post the summary with zeros on the “total” line.

Employers must post the Form 300a in a visible and easily accessible area of their business where employee notices typically are displayed. They must also make a copy of Form 300A available to employees who don’t regularly report to a fixed establishment, such as construction workers who move between worksites. In addition, current and former employees are entitled to a copy of either form upon request. Neither Cal/OSHA nor the federal Occupational Safety and Health Administration (OSHA) have posted any updated guidance for employers about posting the Form 300a during the COVID-19 pandemic when many workplaces are remote.

Electronic Reporting Due March 2

Cal/OSHA also requires certain California employers to electronically submit Form 300A data to the federal OSHA. Employers must electronically report their 2020 Form 300A by March 2, 2021, if they:

  • Employ 250 or more workers, unless specifically exempted by California Code of Regulations Title 8, Section 14300.2.
  • Employ 20 to 249 workers in the industries listed in Appendix H of Cal/OSHA’s related regulations.

Electronic reporting doesn’t change the requirement that all employers keep and maintain Form 300Form 300A and Form 301 for five years, regardless of their size.

Katie Culliton, Editor, CalChamber