29 CFR § 1904.32
Annual summary
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What does 29 CFR § 1904.32 require?
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 text (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.
Read full regulation at eCFR.govWho must comply with 29 CFR § 1904.32?
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 you violate 29 CFR § 1904.32?
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.
Penalty range
Annual citations
YoY penalty trend
How to comply (implementation checklist)
- 1Review the OSHA 300 Log for accuracy each January.
- 2Complete Form 300A with totals for the prior calendar year.
- 3Have a company executive (per definition) sign the certification box.
- 4Post Form 300A in conspicuous locations at each establishment by February 1.
- 5Leave posted through April 30 — minimum 3-month posting period.
- 6Provide a copy to any current or former employee upon request.
- 7Retain the completed 300A for 5 years after the calendar year covered (29 CFR 1904.33).
- 8For 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).
- 9Confirm 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.
Real enforcement examples
Anonymized from public OSHA enforcement summaries. Penalty amounts reflect assessed and final settled values where disclosed.
Manufacturing facility received $32,400 OSHA penalty in 2024 after a complaint-driven inspection found no Form 300A posted in February. The summary had been completed but was filed in the safety office rather than posted in the break room.
Source: OSHA establishment inspection data, anonymized
How FileFlo handles 29 CFR § 1904.32
FileFlo's compliance rule-pack OSHA-29CFR1904.32 automatically checks every document you upload against this regulation. Auto-detects document type, parses key fields, sets renewal alerts, and surfaces this section in your audit binder if a gap is found.
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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.
Related regulations
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Sources + reviewer
Primary source: eCFR.gov: 29 CFR § 1904.32
Reviewed by Chad Griffith (Founder + CEO, FileFlo) on