OSHA 300A Certification Checklist Before an Executive Signs

Before a company executive signs Form 300A, review the 300 Log for completeness and accuracy, correct deficiencies, and reconcile the summary totals. The executive certifies a reasonable belief that the annual summary is correct and complete, based on examining the log and knowing how the information was recorded.

A signature is not a substitute for that review. Build a small packet that explains the numbers and unresolved questions, then leave enough time for the executive to ask for corrections.

This guide addresses the federal recordkeeping framework. Start by confirming whether records are required: the small-company exemption generally applies when the entire company had 10 or fewer employees throughout the previous calendar year. Industry exemptions and specific written recordkeeping requests also matter. This is a different test from establishment-level electronic filing.

State Plan requirements can be more stringent or supplemental in areas described by 1904.37. Check the applicable state agency, especially for public-sector employers. This article does not establish that the software supports every jurisdiction.

When records are required and there were no recordable cases, enter zeros in the case-total columns; still complete the establishment, employment, and hours information. Zero cases do not remove the certification and posting duties for an establishment required to maintain those records.

1. Review the log: examine entries as extensively as needed to confirm completeness and accuracy. Check classifications, duplicate entries, and available updates.
2. Reconcile the totals: make the 300A totals agree with the reviewed 300 Log. Keep the source log and review notes available to the certifier.
3. Confirm establishment details: check the covered year, company and establishment names, address, and the correct establishment’s records.
4. Support employment and hours: retain the annual-average employee calculation and the basis for total hours worked. These are different figures from the headcount used to test electronic-filing coverage.
5. Check the form: compare any equivalent summary with the official 300A, including its employee-access and employer-penalty statements.
6. Resolve questions: document remaining issues and permitted estimates without implying an ongoing injury case must be medically closed.
7. Plan posting: name the person responsible for putting the certified summary where employee notices are customarily posted and keeping it visible.

This packet is a practical review aid. It is not an additional OSHA form, a substitute for the official instructions, or a guarantee of compliance.

Under 1904.32(b)(4), the certifier must be an owner of a sole proprietorship or partnership, a corporate officer, the highest-ranking company official working at the establishment, or that official’s immediate supervisor. A safety or HR job title alone does not establish eligibility.

The preparer and certifier can be different people. Give the certifier access to the log and the supporting process; do not route only a detached signature page.

For 2026 records, post the certified summary no later than February 1, 2027, and keep it posted through April 30, 2027. Use a conspicuous location where employee notices are normally posted and ensure it is not altered, defaced, or covered. The annual summary is the posting document; do not substitute a log containing individual case details.

Use 1904.41 and OSHA’s current instructions to classify each establishment:

• 20–249 employees: 300A information for establishments in Appendix A industries.
• 250 or more employees: 300A information when the establishment is required to keep records.
• 100 or more employees in Appendix B industries: 300 and 301 information in addition to the required 300A information.

The thresholds concern employment at any time in the previous calendar year, not the annual-average employee number on the 300A. Include the employee categories specified by OSHA. Partial exemptions and individual OSHA collection notices can change the answer; do not decide coverage from headcount alone. The electronic requirements also apply in State Plan states.

March 2, 2027 is the electronic deadline for covered establishments under the current rule. See the 2027 preparation calendar for the separate workstreams.

A fictional reviewer finds that a summary total differs from the source log because the same case was entered twice. The reviewer resolves the duplicate in the source records, recalculates the summary, and explains the correction in the packet. The qualifying executive examines the corrected log and summary before certifying. Software can organize the records, but a person must resolve the underlying facts.

300log provides a workspace for organizing establishment records and preparing reports. Start with one establishment and compare the prepared output with the reviewed source records and official form instructions. Keep the employer’s review, executive certification, and filing confirmation as separate steps.

Open the recordkeeping workspace or compare the Free Edition and plans. A generated PDF or CSV is an output, not proof of certification, posting, or successful filing. Confirm the forms and workflow available in your account; do not assume an export button transmits data to OSHA.

Plan the 2027 posting and filing season, compare Forms 300, 300A and 301, or use the deadline calendar to assign the next task.