300A certification

OSHA 300A Certification Packet: What Executives Should Review Before Signing

A certification packet should let the executive reasonably believe the 300A is correct: the reviewed log, totals, employee and hours sources, and open issues.

Updated 4 min readBy 300log Editorial Team
Fountain pen on a document with an evergreen wax seal

The short answer

A certification packet should let the executive reasonably believe the 300A is correct: the reviewed log, totals, employee and hours sources, and open issues. It turns the signature into a decision rather than a formality.

The signature should follow a review of completeness, accuracy, and supporting totals.

What the rule requires

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 to look for

Give the certifying executive a packet with log review notes, totals, average employees, hours worked, the posting plan, and open issues. 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.

Whatever you use should make these easy to keep and retrieve:

  • 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

How to evaluate your options

  1. Assemble the packet.
  2. Resolve or explain exceptions.
  3. Route it for certification.
  4. Keep the posting evidence with the packet.

As the certifying executive you are attesting to the process, so ask to see how the numbers were checked, not just the totals.

What to watch for

Keep these in mind when you compare approaches:

  • Teams ask for a signature without explaining the recordkeeping basis.
  • Late case changes can undermine a signed summary if the packet is not updated.
  • Cases still open at year end are recorded with estimated day counts and updated later; the certified summary does not have to be redone.

Paper, spreadsheet, or software?

Spreadsheets fail quietly: a sort that renumbers rows, a tab copied for the new year, a formula that misses a new column. None of that shows on the printed form, which is why any system, including a spreadsheet, should be tested on real historical cases before it is trusted.

Example

A plant manager's packet is four pages: the draft 300A; the log with review initials on each case; a note that two cases have estimated day counts; and the payroll report behind 486,000 hours worked, with holiday pay removed. The manager asks one question about an estimate, gets the answer, and certifies.

Where 300log fits

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

Does each establishment need its own certified 300A?

Yes. Each establishment with its own log gets its own summary, certified and posted at that establishment.

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. [1]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
  2. [2]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
  3. [3]29 CFR 1904.33: Retention and updatingOccupational 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.

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Keep the log, the 301s and the 300A in one place

300log turns each case into its OSHA 300 Log entry and 301 report, keeps privacy cases off the shared log, totals the 300A and files it with OSHA's ITA for you as soon as you authorize it.