29 CFR § 1904.32 — Annual summary
29 CFR — Labor · OSHA / DOL
29 CFR 1904.32 is the OSHA 300A annual summary requirement. Every covered employer (generally, businesses with 10+ employees in non-exempt industries) must post the Form 300A in a visible location at each workplace from February 1 through April 30 each year — covering the prior calendar year's recordable injuries. A company executive certifies the accuracy. Even ZERO injuries requires posting a zero-summary 300A. Missing the Feb 1 posting deadline is among the most common and most easily-cited OSHA violations — the inspector simply looks for the posted form.
Regulation summary
At the end of each calendar year, each covered employer must (a) review their OSHA 300 Log of Work-Related Injuries and Illnesses for accuracy and completeness, (b) create an annual summary (Form 300A) of the prior year's recordable injuries and illnesses, (c) have a company executive certify the summary's accuracy, and (d) post the Form 300A in a conspicuous location at each covered establishment between February 1 and April 30 of the following year. The summary must remain posted for the entire 3-month period. Even if the establishment had zero recordable injuries, a Form 300A with 'zero' entries must still be posted.
Who must comply
Most private-sector employers with 10+ employees in non-partially-exempt industries. Partial exemptions cover certain low-hazard industries (e.g., most retail, finance, insurance, real estate, services). Employers must check their NAICS code against OSHA's partial-exemption list. Federal, state, and local government employers also have recordkeeping obligations but specifics vary.
What happens if violated
OSHA civil monetary penalties for serious violations: $16,131 per violation (2025). Repeat or willful: up to $161,323. Posting violations are typically classified as 'other-than-serious' but can escalate quickly when patterns are found. CSHO citations require posting/abatement within 30 days. Multiple recordkeeping violations across an establishment can trigger broader inspections.
Implementation checklist
- Review the OSHA 300 Log for accuracy each January.
- Complete Form 300A with totals for the prior calendar year.
- Have a company executive (per definition) sign the certification box.
- Post Form 300A in conspicuous locations at each establishment by February 1.
- Leave posted through April 30 — minimum 3-month posting period.
- Provide a copy to any current or former employee upon request.
- Retain the completed 300A for 5 years after the calendar year covered (29 CFR 1904.33).
- For employers above electronic submission thresholds (250+ employees or specific high-hazard industries), submit to OSHA's ITA portal by March 2 (29 CFR 1904.41).
- Confirm establishment NAICS code is not on the partial exemption list.
Common misinterpretations
- Misinterpretation: 'We had no injuries — we don't need to post anything.' Reality: A zero-injury year still requires a Form 300A with zero values posted. The form itself must be posted regardless of injury count.
- Misinterpretation: 'Posting it on the company intranet is enough.' Reality: 29 CFR 1904.32(b)(5) requires posting in a CONSPICUOUS LOCATION where notices to employees are customarily posted (typically the break room or main employee bulletin board). Online-only posting does not satisfy the rule for most employers.
- Misinterpretation: 'February 1 is just the goal — early March is fine.' Reality: February 1 is the regulatory deadline. Late posting is a citable violation. Most OSHA inspectors check for the 300A posting in any opening conference.
- Misinterpretation: 'A manager can certify the 300A.' Reality: 29 CFR 1904.32(b)(4) requires a COMPANY EXECUTIVE to certify — defined as an owner, officer of the corporation, highest-ranking company official at the establishment, or that official's immediate supervisor. A line manager or safety coordinator does not satisfy this.
Frequently asked questions
What is the OSHA Form 300A?
The Annual Summary of Work-Related Injuries and Illnesses. A one-page summary derived from the OSHA 300 Log, showing totals for the prior calendar year. Must be posted at each establishment from February 1 through April 30 each year.
What employers must post the 300A?
Most private-sector employers with 10+ employees, excluding industries on OSHA's partial-exemption list (most retail, finance, services). Check your NAICS code against OSHA's list at https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html.
What if I had no recordable injuries?
You still must post a Form 300A with zero values. The form itself must be posted regardless of injury count. Failing to post zero-injury 300As is a common citation.
Where must the 300A be posted?
In a conspicuous location at each establishment where notices to employees are customarily posted — typically the break room, time clock area, or main bulletin board. Online-only posting (intranet) does not satisfy the rule for most employers.
How long must the 300A be posted?
From February 1 through April 30 — a 3-month posting period at minimum. Many employers leave it posted year-round.
Who must certify the 300A?
A company executive: owner, officer of the corporation, highest-ranking company official at the establishment, or that official's immediate supervisor. Line managers and safety coordinators do not satisfy this requirement.
Do I need to submit the 300A to OSHA electronically?
Some employers do, under 29 CFR 1904.41 — establishments with 250+ employees and certain high-hazard industries with 20-249 employees. Submission deadline is March 2 each year via OSHA's Injury Tracking Application (ITA).
How long must I keep the completed 300A?
5 years after the end of the calendar year the summary covers, per 29 CFR 1904.33.
Cross-references: 29 CFR 1904.4 · 29 CFR 1904.7 · 29 CFR 1904.35 · 29 CFR 1904.41
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