Federal agency injury summary certification

The certifier must be one of three Federal officials: the senior establishment management official, the head of the Agency, or any management official in the direct chain of command between the senior establishment management official and the head of the Agency. See 1960.67 which sets out those three specific options and explains that they are intended to be equivalent to the private-sector certifiers named in 1904.32(b)(4).

The certifier must personally review the OSHA 300 Log (or equivalent records) and be satisfied, based on their knowledge of how the entries were recorded, that the annual summary is correct and complete. The requirement comes from 1904.32 and is restated for Federal agencies in 1960.67. In practice, this means the certifier should:

• Inspect the OSHA 300 Log or equivalent forms for accuracy and completeness.
• Understand the recordkeeping process (who records, how entries are verified, and what supporting documentation exists).
• Rely on that review and knowledge when signing the certification.

No — certification must be performed by one of the officials listed in 1960.67 (senior establishment management official, the head of the Agency, or a management official in the direct chain of command between them). The Federal rule adapts the private-sector requirement in 1904.32 to Federal position titles, and it does not authorize delegation outside the identified Federal officials. If a non-listed administrative person prepares the records, the named certifier must still review and sign based on their knowledge of the recording process.

Yes — a management official who is in the direct chain of command between the senior establishment management official and the head of the Agency is an approved certifier under 1960.67(c). The regulation explicitly lists that position as an acceptable person to perform the certification, so that official may sign when the senior establishment management official is unavailable.

Yes — the certifier should confirm that any electronic or software-generated forms are equivalent to OSHA forms before relying on them for certification. OSHA has said that software-generated forms may substitute for OSHA Form 300 and Form 300A if they meet the equivalency requirements in 29 CFR 1904.29 (discussed in the April 29, 2025 letter of interpretation). See the letter, Software-generated OSHA recordkeeping forms, which explains that equivalent forms must contain the same information, be as readable and understandable, and be completed using the same instructions as the OSHA forms.

Yes — software-generated documents are acceptable if they meet OSHA's equivalency rules for replacing OSHA forms. OSHA's April 29, 2025 interpretation, Software-generated OSHA recordkeeping forms, explains that employers may use equivalent electronic forms so long as the forms contain the same information, are as readable and understandable, and follow the same instructions as OSHA Form 300 and Form 300A (see 1904.29 for the underlying recordkeeping rule). Certifiers should ensure the electronic system can produce those equivalent forms when needed.

Yes — records, including equivalent electronic forms, must be made available for inspection and copying as required by OSHA. The Software-generated OSHA recordkeeping forms interpretation reiterates that equivalent forms must be available for inspection and copying under 1904.40 and must be provided to employees under 1904.35. A certifier should ensure the records they reviewed (electronic or paper) can be produced on request.

The certifier should verify the accuracy of the OSHA 300 Log (or equivalent), understand who prepared entries and how they were checked, and confirm that supporting documentation exists for recorded cases. This follows the requirement in 1904.32 that the certifier has "examined the OSHA 300 Log" and believes, based on their knowledge of the process by which information was recorded, that the annual summary is correct and complete. Useful review steps include:

• Checking that entries match incident reports and medical documentation where applicable.
• Confirming that recordability decisions followed the Part 1904 rules.
• Verifying that equivalent electronic forms produce the same data if software is used (see Software-generated OSHA recordkeeping forms).

Section 1960.67 maps Federal agency position titles to the private-sector certifier requirement in 1904.32(b)(4). The note to 1960.67 explains that Federal titles do not match private-sector titles, so the listed Federal officials are intended to be their equivalents for the certification required by 1904.32.

Yes — Federal establishments that maintain OSHA injury and illness records are subject to the certification requirement as described in 1960.67 and the underlying recordkeeping rule at 1904.32. The Federal rule exists because private-sector certifier titles in Part 1904 do not match Federal agency titles, so 1960.67 specifies which Federal officials must perform the certification.

Yes — the head of the Agency is an authorized certifier under 1960.67(b), but their certification must still comply with the requirement in 1904.32 that they have "examined the OSHA 300 Log" and believe, based on knowledge of the recording process, that the summary is correct and complete. If the Agency head lacks the necessary knowledge, they should review the recordkeeping process information or rely on an appropriate management official in the chain who has that knowledge before signing.

No — the certifier must have examined the OSHA 300 Log and have knowledge of the process by which the information was recorded before signing, as required by 1904.32 and reiterated for Federal agencies in 1960.67. Signing without review would not satisfy the regulation's requirement that the certifier believes the summary is correct and complete based on their knowledge of the recording process.

Yes — if the establishment uses software to keep records, the certifier should ensure that the system can produce equivalent OSHA forms on demand for employee access and government inspection. OSHA's Software-generated OSHA recordkeeping forms interpretation clarifies that electronic systems may be used provided they produce equivalent forms consistent with 1904.29 and that those forms must be available for inspection under the access provisions in 1904.35 and 1904.40.

Establishments required to submit electronically must send their Form 300A data to OSHA annually; OSHA's enforcement guidance reminds employers that the submission deadline is March 2 for the prior calendar year. See the enforcement memorandum, Electronic injury record submission enforcement, which explains the March 2 deadline and related enforcement timing, and see 1904 for the underlying recordkeeping rule.

The regulation specifies Federal agency officials (senior establishment management official, head of the Agency, or a management official in the direct chain of command) as the appropriate certifiers in 1960.67; it does not authorize an outside contractor to perform the certification unless that contractor occupies one of those listed Federal positions. The certification must reflect a Federal official's review and belief about the log's completeness and accuracy, consistent with 1904.32.