Dealers No Longer Exempt – OSHA Electronic Reporting/Posting Mandate

Feb 28, 2018 | Member News

As part of the Occupational Safety and Health Administration (OSHA) reporting mandate, which took effect in 2017, dealers are required to post their 2017 OSHA 300A Summary Form in a prominent area at the workplace by February 1, 2018. The posting can be taken down after April 20, 2018.

 Under the OSHA Recordkeeping regulation, employers with 10 or more employees are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log. Beginning February 1 and ending April 30, each year, a summary of the injuries/illnesses entered on the previous years OSHA 300 Log is required to be posted using OSHA Form 300A-Summary of Work-Related Injuries and Illnesses.

 Below are frequently asked questions and answers:

 What does the OSHA rule on the tracking of workplace injuries and illnesses do?

The May 12, 2016, rule revises OSHA’s mandates for the recording and reporting of occupational injuries and illnesses by requiring that certain dealerships electronically submit the injury and illness forms they presently must keep on file. OSHA intends to make these forms publicly available on its website and to use them to target its enforcement efforts. The rule also mandates that all dealerships maintain reasonable procedures for the prompt and accurate reporting of employee workplace injuries and illnesses and inform employees of those procedures.

 Lastly, all dealerships must inform employees of their right to report work-related injuries and illnesses and that they will not be discriminated against for doing so.

 Aren’t dealerships exempt from posting the OSHA 300 Log?

Dealerships lost their exception from this rule in 2015. A dealerships first report should have been kept on record and posted in 2016. Dealers are reminded that this posting requirement is every year from February 1 to April 20.


What is required of the dealership?

At the end of each calendar year, each dealership location must:

1.       Review the entries on the OSHA 300 Log and ensure that all information is complete and accurate.

2.       Create an annual summary of injuries/illnesses using the OSHA 300A Summary Form.

3.       Certify the OSHA 300A Summary Form.

4.       Post the OSHA 300A Summary Form in a conspicuous area(s) where employees normally see postings. Between February 1 and April 30 postings cannot be altered, defaced, or covered by other material.


Where can the dealership locate the OSHA forms?

OSHA Recordkeeping forms can be found on the OSHA website, PAA partner KPA also has OSHA forms available within the accident tab on


Can the dealership post the OSHA 300 Log with the Summary Form?

Yes, but if the posting area is accessible by others (i.e., members of the public) the employer must remove or hide all names of the injured or ill employees.


Does the dealership have to send injury/illness information to OSHA by February 1?

No, but paperwork associated with occupational injuries/illnesses must be retained onsite or online for a minimum of five years.


Which dealerships must electronically submit injury and illness forms to OSHA?

The answer depends on whether you are a light-duty (car and light-truck) or commercial truck dealership.

  • Car dealerships with fewer than 250 employees at a single “establishment” are not required to submit forms to OSHA. 
  • Commercial truck dealerships with 20 to 249 employees at a single “establishment” must electronically submit to OSHA their annual summary of employee workplace injuries and illnesses (Form 300A or equivalent).
  • Car and commercial truck dealerships with 250 or more employees at a single “establishment” (which is rare) must electronically submit to OSHA Form 300A and all of their injury and illness recordkeeping forms (Forms 300, 300A and 301 or equivalent) each year.

All dealerships with 10 or more employees must continue to accurately record and post employee workplace injury and illnesses using OSHA Forms 300, 300A, and 301 (or the state equivalent) and must continue to make those forms available to OSHA and state labor inspectors upon request.


Courtesy of PAA Bulletin No. 4, 2/22/2018