Bryan Little, Farm Employers Labor Service

January 15, 2020

The Division of Occupational Safety and Health of the California Department of Industrial Relations (Cal/OSHA) requires covered all employers to post their Form 300A injury and illness summary information from the previous year between February 1 and April 30 if the employer had at least 11 employees at any time in the prior year. 

In addition, agricultural employers must electronically submit Form 300A data for calendar year 2020 between January 2, 2021 and March 2, 2021 to the federal Occupational Safety and Health Administration (OSHA) Injury Tracking Application if the employer employed more than 20 employees at any time in the prior year, as required by a Cal/OSHA rule adopted in December 2019.  

Work-related COVID-19 cases may trigger recording and reporting obligations, which would impact the 300A data. Cal/OSHA has released Frequently Asked Questions (FAQ) on how employers are expected to determine recordability (as a workplace illness or injury) and reportability of COVID-19 cases.  In those FAQ, the agency notes: “A work-related exposure in the work environment would include interaction with people known to be infected with SARS-CoV-2 (the virus that causes COVID-19); working in the same area where people known to have been carrying SARS-CoV-2 had been; or sharing tools, materials or vehicles with persons known to have been carrying SARS-CoV-2.”  You can read these FAQ at: (https://www.dir.ca.gov/dosh/coronavirus/Reporting-Requirements-COVID-19.html.)