Posting 2001 injury summary

You had to post a 2001 annual summary if you were required to keep OSHA 200 Logs in 2001 for that establishment. The rule is explicit that employers who were required to keep OSHA 200 Logs in 2001 must post a 2001 annual summary for each establishment, see 1904.43(a).

The 2001 summary must include the totals from the 2001 OSHA 200 Log and four specific items: the calendar year covered, your company name, the name and address of the establishment, and the certification signature, title, and date. The rule lists these required items in 1904.43(b)(1)(i) and the individual elements in 1904.43(b)(1)(i)(A), 1904.43(b)(1)(i)(B), 1904.43(b)(1)(i)(C), and 1904.43(b)(1)(i)(D).

You must enter zeros on the totals line and post the 2001 summary. The regulation requires that if no injuries or illnesses occurred at your establishment in 2001, you still complete the summary by entering zeros on the totals line and post it, see 1904.43(b)(1)(ii).

You had to complete the 2001 summary by February 1, 2002, and post a copy in each establishment in a conspicuous place where notices to employees are customarily posted. The rule sets the completion deadline in 1904.43(b)(2)(i) and the posting location and requirement that the summary not be altered, defaced, or covered in 1904.43(b)(2)(ii).

The 2001 summary had to be posted from February 1, 2002 through March 1, 2002. The regulation states the required posting period explicitly in 1904.43(b)(3).

You generally must post a copy in each establishment where notices are customarily posted, so an intranet-only posting would not automatically meet the requirement unless employees customarily get workplace notices that way. The regulation requires posting a copy "in each establishment in a conspicuous place or places where notices to employees are customarily posted," 1904.43(b)(2)(ii). If you use electronic records or software to create the summary, OSHA permits electronic systems to produce equivalent forms provided they meet the equivalent-form requirements; see OSHA's letter on Software-generated OSHA recordkeeping forms which explains employers may keep records electronically and produce equivalent printed forms when needed.

The certification must include a signature, the signer's title, and the date. The text of the rule requires the certification signature, title, and date be included on the 2001 summary, 1904.43(b)(1)(i)(D). The provision specifies the information the certification must contain but does not name a specific job title or officer who must sign; employers must ensure the summary contains a valid signature, an identifying title for the signer, and the date.

Yes — you must post a 2001 annual summary for each establishment that was required to keep OSHA 200 Logs in 2001. The regulation states employers must post a 2001 annual summary "for each establishment," 1904.43(a).

The summary must show your company name and the name and address of the specific establishment covered by that summary. The regulation requires inclusion of your company name in 1904.43(b)(1)(i)(B) and the establishment's name and address in 1904.43(b)(1)(i)(C), so the posted summary for each site should clearly identify both the company and the specific establishment location being summarized.

Common places include employee bulletin boards, break rooms, near time clocks, or other locations where workplace notices and safety information are normally posted and visible to employees. The regulation uses the phrase "conspicuous place or places where notices to employees are customarily posted," so choose locations employees regularly pass and check, as required in 1904.43(b)(2)(ii).

Post the summary in a protected, clearly visible place and take simple safeguards so it remains legible and accessible. For example, place it on a designated safety bulletin board, use a protective cover or frame, post the summary where it won't be routinely covered by other notices, and periodically check the posting during the required period to ensure it has not been altered or defaced, consistent with the requirement in 1904.43(b)(2)(ii).

Yes — you may use software-generated or electronic records to produce the 2001 summary as long as the electronic form produces an equivalent printed summary that meets the recordkeeping and posting requirements. OSHA has clarified that electronic systems and software can be used if they produce equivalent forms that meet the requirements of the recordkeeping standard, see the OSHA letter on Software-generated OSHA recordkeeping forms, and you must still post a copy in the establishment consistent with 1904.43(b)(2)(ii).