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Recordkeeping (29 CFR Part 1904, all covered employers)

Annual Summary (OSHA 300A)

Verified vs OSHA sources · 2026-10-05

29 CFR 1904.32

29 CFR 1904.32 governs the year-end 300-A summary. At the end of each calendar year an employer must review the OSHA 300 Log for accuracy, create the 300-A annual summary of that year's cases, have a company executive certify it, and post the 300-A where notices are usually posted, from February 1 through April 30 of the following year.

29 CFR 1904.32 at a glance

Four steps
Review the 300 Log, create the 300-A, certify it, post it
Who certifies
A company executive attests the Log and summary are accurate
Posting window
February 1 through April 30 of the following year
Where posted
Where employee notices are usually posted, and kept legible
Zero cases
Still post a 300-A showing zeros
Max penalty (2026)
Other-than-serious $16,550; willful $165,514

What 29 CFR 1904.32 requires (plain English)

29 CFR 1904.32 sets the year-end obligations for the OSHA 300-A annual summary. At the close of each calendar year, the employer must (1) review the 300 Log and correct any deficiencies, (2) create the 300-A summary of the year's injuries and illnesses, (3) certify the summary, and (4) post it.

The certification is a specific accountability requirement: a company executive (the owner, an officer, the highest-ranking company official at the site, or that official's immediate supervisor) must sign to certify that they examined the 300 Log and reasonably believe the summary is correct and complete. This pushes recordkeeping accuracy up to a senior level rather than leaving it with a clerk.

The 300-A must be posted where employee notices are customarily posted and kept in place, legible, from February 1 to April 30 of the year following the year covered. Even establishments with no recordable cases must complete and post a 300-A showing zeros. The summary is also the form electronically submitted to OSHA under §1904.41 by covered establishments.

The regulatory text

“At the end of each calendar year, you must: (1) Review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any deficiencies identified; (2) Create an annual summary of injuries and illnesses recorded on the OSHA 300 Log; (3) Certify the summary; and (4) Post the annual summary.”
29 CFR 1904.32(a)

Key facts about 29 CFR 1904.32

  • The year-end steps are review the Log, create the 300-A, certify it, and post it (1904.32(a)).
  • A company executive must certify the summary as correct and complete.
  • The 300-A must be posted from February 1 to April 30 of the following year.
  • It is posted where employee notices are usually placed and kept legible.
  • Even a workplace with zero recordable cases must post a 300-A showing zeros.
  • Only annual totals go on the 300-A: no individual employee names.
  • The 300-A is the form electronically submitted under §1904.41 by covered establishments.

Scope: who 29 CFR 1904.32 applies to

Regulatory framework
Recordkeeping (29 CFR Part 1904, all covered employers)
Citation reference
29 CFR 1904.32
Enforcement status
In force and enforced
Jurisdiction
Federal OSHA (29 State-Plan jurisdictions may be stricter)

State-Plan states (e.g. California, Washington, Michigan) operate OSHA-approved programs that must be at least as effective as federal OSHA and frequently impose higher penalties or additional requirements. Confirm the rule as adopted in your state.

Key requirements of 29 CFR 1904.32

#Employer obligation
1Review 300 Log for accuracy before summarizing
2Complete 300A by February 1
3Post 300A from February 1 through April 30
4Certify summary by company executive
5Post in conspicuous location accessible to employees

Summarized from the text of 29 CFR 1904.32. Always read the full regulation for the binding language.

Common Annual Summary 300A violations

Deficiencies OSHA cites under 29 CFR 1904.32 include the ones below, in no particular order. Distinct deficiencies can be cited as separate items, and each serious item carries up to $16,550 (2026). Broader per-instance stacking exists but is a discretionary, case-by-case OSHA enforcement policy, not an automatic multiplier.

  • No executive certification of the 300-A (1904.32(b)(3)/(4)).
  • Not posting the 300-A, or posting it for less than February 1–April 30 (1904.32(b)(5)/(6)).
  • Not creating a 300-A at all (including a zero summary): 1904.32(a)(2).
  • Failing to review and correct the 300 Log before summarizing (1904.32(a)(1)).
  • Posting the summary where employees cannot readily see it (1904.32(b)(5)).

The 300-A needs an executive's certification and a full three-month posting, not just a printout

Two requirements are frequently missed. First, the 300-A must be CERTIFIED by a company executive (an owner, an officer, the top company official at the site, or that person's immediate supervisor) who signs attesting the Log and summary are accurate. A safety coordinator's signature alone does not meet it; the point is senior accountability. Second, the summary must be POSTED continuously from February 1 through April 30, three full months, where employees see notices, not put up briefly or filed in a binder. And a site with no injuries is not off the hook: it must still post a 300-A showing zeros so workers know the record was kept.

What OSHA inspectors look for

A compliance officer checks that the 300-A was created, certified by a company executive (not just a safety clerk), and posted for the full February 1–April 30 window, including a zero-injury summary if there were no cases. A missing certification signature or a summary taken down early are common findings.

Example: how a violation is cited

An employer fills out the 300-A but the plant manager never signs the certification and it is posted only for two weeks in February. OSHA cites 1904.32 for the missing executive certification and the short posting period, up to $16,550.

Illustrative example, not a specific OSHA case.

Annual Summary 300A compliance checklist

Use this to evaluate your compliance with 29 CFR 1904.32. Each item is a key requirement OSHA may verify during an inspection.

  • Review the 300 Log at year-end and correct any errors or omissions.
  • Create the 300-A summary of the year's recordable cases (or zeros).
  • Have a company executive certify the summary as correct and complete.
  • Post the 300-A from February 1 through April 30 where employee notices are posted.
  • Keep the posted summary legible for the full period.
  • Electronically submit the 300-A to OSHA under §1904.41 if your establishment is covered.

2026 penalties for 29 CFR 1904.32

Maximums set by 29 CFR 1903.15(d). 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The 2025 OSHA penalty levels remain in effect for 2026; OSHA made no inflation adjustment for 2026. 29 CFR 1903.15 identifies January 15, 2025 as the effective reference for these amounts, while OSHA's public penalties page currently references penalties assessed after Jan. 15, 2026.

Violation typeMinimumMaximumWhen it applies
Serious$1,085$16,550Substantial probability of death or serious physical harm.
Other-Than-Serious$0$16,550Relates to safety/health but unlikely to cause death or serious harm.
Willful$11,823$165,514Intentional, knowing, or voluntary disregard of the requirement.
Repeated$4,256$165,514A substantially similar violation cited within the last 5 years.
Failure to AbateNone$16,550/dayup to $16,550 per day; total capped at 30x the daily amount (FOM Ch.6)

Failure to create, certify, or post the 300-A for the full period is cited as other-than-serious, up to $16,550; willful violations reach $165,514.

Maximums and the willful minimum are set by 29 CFR 1903.15(d); the serious and repeated minimums are OSHA policy floors from its annual penalty adjustment memo. OSHA applies gravity-based and size, good-faith and history reductions (FOM CPL 02-00-164 Ch.6). Estimates only, not legal advice.

The business case for Annual Summary 300A compliance

The annual summary is the one piece of injury data workers actually see. Posting it makes the workforce aware of the site's injury experience, and the executive certification forces a senior official to attest that the Log is accurate: a deliberate accountability step. Even a workplace with zero recordable cases must post a 300-A showing zeros, so employees know the record was kept.

Free compliance tools for 29 CFR 1904.32

OSHA 300A Auto-FillerOSHA Deadline CalendarOSHA Recordability Decision Tree

Annual Summary 300A penalties by state

Penalties and enforcement vary by state. State-Plan states may impose higher penalties and additional requirements beyond federal 29 CFR 1904.32.

AlabamaArkansasColoradoConnecticutDelawareDistrict of Columbia
View all 50 states + DC →

Frequently asked questions about 29 CFR 1904.32

When must the OSHA 300-A be posted?

Under 1904.32, the 300-A annual summary must be posted from February 1 through April 30 of the year following the year it covers. It goes where employee notices are usually posted and must be kept legible for the full three-month period. This applies even if there were no recordable cases: you post a 300-A showing zeros.

Who has to certify the 300-A summary?

A company executive. Under 1904.32, certification must be signed by the owner, an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor. They attest that they examined the 300 Log and reasonably believe the summary is correct and complete. A safety clerk's signature does not satisfy the requirement.

Do I post the 300-A if we had no injuries?

Yes. Even establishments with zero recordable injuries or illnesses must complete and post a 300-A showing zeros, from February 1 to April 30. Posting the zero summary tells employees that the record was kept and that there were no recordable cases that year.

What is the difference between the 300 Log and the 300-A?

The 300 Log is the detailed running list of each recordable case during the year, including some case specifics. The 300-A is the annual summary: it shows only the yearly totals by category, with no individual case detail or names, and it is the form that gets certified, posted for employees, and electronically submitted to OSHA.

Regulatory history of 29 CFR 1904.32

The 300-A annual summary, its executive-certification requirement, and the February 1–April 30 posting window took effect January 1, 2002 (66 FR 5916). The executive certification was a notable addition: it made a senior company official personally attest to the accuracy of the injury record, rather than leaving certification to whoever kept the log.

Related glossary terms

Key terms that appear in 29 CFR 1904.32, each with a full plain-English explainer.

Recordable InjuryNational Emphasis ProgramIndustrial HygieneJob Hazard Analysis

Related guides & articles

OSHA Forms 300, 300A & 301 Recordkeeping GuideOSHA Top 10 Most-Cited Violations 2026

Related OSHA standards

29 CFR 1910.1020

Exposure & Medical Records

29 CFR 1904.4

Recording Criteria

29 CFR 1904.5

Work-Relatedness

29 CFR 1904.7

General Recording Criteria

Primary sources

OSHA figures on this page are imported from HazComFast's verified regulatory module (verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register).

This page is an educational summary, not legal advice. OSHA standards and penalty amounts change; confirm requirements against the current regulation and your applicable State-Plan before acting.

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OSHA does not give advance notice of inspections (29 CFR 1903.6). Get the binder in order before the opening conference, not during it.

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