Who Must Sign the OSHA 300A Summary?
Only a company executive can certify the 300A: an owner, a corporate officer, the top company official at the site, or that official's supervisor.
Quick answer
Only a company executive can certify the 300A: an owner, a corporate officer, the top company official at the site, or that official's supervisor. Owners qualify only in sole proprietorships and partnerships, and the certifier must have examined the log and reasonably believe the summary is correct and complete.
The signature is a governance control, not a clerical last step.
The rule in plain English
At the end of each year you review the 300 Log, total it on the 300A, and have a company executive certify the summary before it is posted (29 CFR 1904.32). By certifying, the executive states that they have examined the log and reasonably believe, based on their knowledge of how the information was recorded, that the summary is correct and complete. Only four kinds of people qualify: an owner (sole proprietorships and partnerships only), an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor.
What this looks like in practice
Route the 300A to a qualifying company executive after the log review is complete. Certification is where a weak review process becomes a signed statement, so the packet the executive sees matters as much as the signature. The fix is to route the 300A with the review behind it: open cases, the sources for employees and hours, and what changed since the last review.
HR leaders sit where recordkeeping meets policy: how employees report, how cases are discussed, and how discipline and incentives are designed.
The mistake to avoid
Teams often have the EHS manager sign because that person prepared the numbers.
The certified 300A is what gets posted and, for covered establishments, what gets submitted to the ITA, so the signature covers both.
Edge cases worth checking
- For remote or branch sites, the highest-ranking company official working at that establishment is often the right certifier.
- Cases still open at year end are recorded with estimated day counts and updated later; the certified summary does not have to be redone.
Example
At a branch of a national distributor, the branch manager is the highest-ranking company official working there, so the branch manager can certify. The regional director (the branch manager's immediate supervisor) could also sign. The branch's EHS coordinator, who prepared the summary, cannot.
Step by step
- Finish the log review.
- Prepare the totals and supporting figures.
- Route them to a qualifying executive.
- Certify, then post by February 1.
What to keep in the case file:
- Review notes showing each case was checked
- Totals, annual average employees, and hours worked, with their sources
- The certifier's name, title, and date on the 300A
- A list of open cases and how their estimated day counts were set
Where 300log helps
300log builds each establishment's 300A from its log, shows which incidents are still in progress, and records the certifying executive's name, title, and date on the summary.
For a quick answer without an account, use the free deadline calendar.
Frequently asked questions
Who Must Sign the OSHA 300A Summary?
Only a company executive can certify the 300A: an owner, a corporate officer, the top company official at the site, or that official's supervisor. Owners qualify only in sole proprietorships and partnerships, and the certifier must have examined the log and reasonably believe the summary is correct and complete.
Do we recertify if a case changes after posting?
No. You must update the 300 Log during the retention period, but updating the 300A is optional (29 CFR 1904.33(b)(2)).
Who can certify the OSHA 300A?
An owner of a sole proprietorship or partnership, an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor (29 CFR 1904.32(b)(4)).
Can the safety manager sign the 300A?
Only if they are also one of the four qualifying executives. Preparing the numbers does not qualify someone to certify them.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA injury and illness recording overviewOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.
