Employers should be aware that important state and federal Occupational and Health Safety Administration (OSHA) deadlines require them to post 2018 Log 300A today at their work sites, and submit them electronically by March 2.
There has been much confusion with respect to an employer’s obligation to submit various OSHA record-keeping forms. While the dust has not fully settled, the following requirements are currently in place:
- California law requires employers to post their 2018 OSHA Log 300A beginning Feb. 1 and through April 30. The Log 300A document must be displayed in a common area where notices to employees usually are posted. Employers must also make a copy of the summary available to employees who move from worksite to worksite, as well as employees who do not report to any fixed establishment on a regular basis.
- Federal law now requires employers to submit their 2018 OSHA Log 300A electronically no later than March 2, 2019. This includes employers with 20 to 249 employees in the specific industries: general medical and surgical hospitals, psychiatric and substance abuse hospitals, ambulatory health care services, and other health care providers.
Last week, the federal Occupational Safety and Health Administration (OSHA) issued a final rule rescinding its requirement that specified health care employers electronically submit OSHA Logs 300 and 301. Employers must, however, continue to complete and maintain those logs at the workplace.
It is possible that California will resurrect the obligation to electronically submit Logs 300 and 301. In 2018, Assembly Bill 2334 added Labor Code 6410.1, requiring Cal/OSHA to convene an advisory committee to evaluate how to protect the goals of the 2016 federal OSHA rule if that rule was rescinded. Because the federal OSHA rule has now been rescinded, Cal/OSHA is expected to convene an advisory committee. CHA will participate in the advisory committee process.