The OSHA 300A Summary: What 'Posting' Actually Requires

A shop owner finishes the year-end recordkeeping ritual: tallies the OSHA 300 log, submits the data through the Injury Tracking Application before the March 2 deadline, and closes the folder. Weeks later, an inspector asks where the 300A summary is posted. The owner points to the filing cabinet. That's the wrong answer, and it's a more common one than the electronic filing requirement gets credit for, because submitting data to OSHA and posting a summary for employees are two separate obligations under two different parts of the same recordkeeping rule, and satisfying one does nothing toward the other.

Submission and posting are not the same requirement

29 CFR 1904.41 governs electronic submission — sending Form 300A data to OSHA's Injury Tracking Application, required annually of establishments that meet the size and industry thresholds. That's a data transfer to a federal database. 29 CFR 1904.32, by contrast, is a physical-workplace requirement: the employer must post a copy of the OSHA Form 300A, the annual summary, in each establishment where records are kept, in a conspicuous location where notices to employees are customarily posted. It exists so that the people who generated the injury and illness data — the workforce — can see the aggregate result, not just the government.

An establishment can be perfectly compliant with 1904.41 and still be cited for 1904.32. The ITA submission proves nothing about what's on the breakroom wall. Inspectors know this and check both independently, because the two rules serve different audiences: one informs OSHA, the other informs employees.

What has to physically go up, and what doesn't

The posted document is specifically Form 300A, the summary page — total case counts, days-away figures, and the breakdown by injury type, aggregated for the year. It is not the 300 log itself, which lists individual incidents with enough detail (job title, description of the injury, body part affected) that posting it raises privacy concerns 1904.32 was written to avoid. A common mistake is photocopying the full log and pinning it up because it feels more thorough. That's backwards: the log stays in the employer's records, available to employees and their representatives on request under 1904.35, but the wall posting is the summary only.

If a small business genuinely had zero recordable injuries or illnesses for the year, the 300A still has to go up, with zeros entered in the case-count fields. "Nothing to post" is not an option 1904.32 recognizes. A blank wall where the summary should be reads, to an inspector, exactly like a missing summary — there's no exemption for a clean year, and skipping the posting because there's "nothing to report" is itself the violation.

The window: February 1 through April 30

The summary covers the prior calendar year and must be posted no later than February 1 of the following year, and kept up through April 30 — a full three months. This window matters on both ends. Posting late, even by a few days, is a 1904.32 violation regardless of how accurate the eventual posting is. Taking it down early — say, pulling it in March because a new poster needs the space — is equally a violation, because the three-month window is itself part of what the standard requires, not a suggestion about when to get around to it.

Outside that window, the rule doesn't require the 300A to stay up, and many businesses take it down once April 30 passes. That's permitted. What trips employers up is the other direction: treating "posted sometime during the year" as good enough, when the standard specifies the exact 90-day span and nothing else satisfies it.

Who has to sign it, and why that's not a formality

Form 300A requires a certifying signature from a company executive, and 1904.32 defines that narrowly: an owner of the company, an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor. A safety coordinator or office manager filling out and signing the form, however competent, doesn't satisfy this if they don't hold one of those positions. The certification isn't paperwork theater — it's a mechanism for accountability. Someone with actual authority over the establishment is attesting, under their own name, that the summary is complete and accurate. Getting the wrong signature on the form is a common enough gap that it's worth checking explicitly rather than assuming whoever usually handles compliance paperwork is the right signatory.

For a business with a single location and an owner-operator who's also the highest-ranking official on-site, this is usually straightforward. It gets less obvious once there's a general manager running day-to-day operations at a site the owner rarely visits — the standard doesn't let the on-site manager sign in the owner's place unless that manager is genuinely the highest-ranking company official working there, not just the most senior person present that day.

Where "conspicuous" actually means something

The standard's language — a place where notices to employees are customarily posted — isn't decorative. It means wherever the business already posts required federal and state labor notices: minimum wage, FMLA, unemployment insurance, that cluster near a breakroom or time clock. Posting the 300A somewhere employees don't naturally look, like an office employees rarely enter, technically checks a box but defeats the purpose the standard is built around, and an inspector walking the floor will notice a summary posted somewhere no one on the shop floor would ever see it.

For businesses with multiple work areas under one roof — a manufacturing floor and a separate office suite, for instance — that can mean more than one posting location if employees in different areas don't share a common space where notices are seen. The rule ties to where employees actually are, not to a single central bulletin board that's convenient for management but invisible to half the workforce.

What an inspector actually checks

When 1904.32 compliance comes up during an inspection, it's rarely the headline issue — it's usually confirmed almost in passing, on the way to something else, precisely because it's easy to verify and easy to get wrong. An inspector will ask to see where the current summary is posted, check the certification signature against payroll or org chart records to confirm the signer's actual title, and compare the posted case counts against the underlying 300 log to make sure the summary wasn't transcribed incorrectly. Any one of those three checks can turn a routine recordkeeping conversation into a citation, and none of them require anything beyond what a business should already have on hand if the posting was done correctly the first time.

The fix for all of this is almost entirely procedural rather than substantive: build the February 1 posting date into whatever calendar already tracks the March 2 ITA submission, confirm the signer is someone who actually qualifies under 1904.32's definition before the form goes up, and leave it exactly where it is until May 1. None of that requires new systems or new expense — it requires treating posting as a distinct, dated obligation rather than an afterthought to the electronic filing that gets all the attention because it has OSHA's name attached to the portal.

The OSHA 300A Summary: What 'Posting' Actually Requires — and How Long It Has to Stay Up