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Standard Interpretations - Table of Contents
• Standard Number: 1904.32(a)(4)

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

January 29, 2009

Ms. Betty Johnson, RN
IBM – Integrative Health Services
3039 Cornwallis Road
Durham, NC 27709

Dear Ms. Johnson:

We are in receipt of your letter dated October 8, 2008 to the Occupational Safety and Health Administration's (OSHA) Atlanta Regional Office. It has been forwarded to OSHA's Directorate of Evaluation and Analysis for answering regarding the Recordkeeping regulation contained in 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses. In an effort to provide you with prompt and accurate responses, we developed and continue to refine a set of Frequently Asked Questions (FAQ), in addition to maintaining a log of Letters of Interpretation (LOI) on the OSHA Recordkeeping website http://www.osha.gov/recordkeeping/index.html.

Question: Prior to posting, is it permissible to use an electronic signature to certify the OSHA 300-A Annual Summary?

Answer: The OSHA recordkeeping regulation does not prohibit the use of electronic signature to satisfy the Annual Summary certification requirement. The certification required by the regulation may be made by either signing and dating the certification section on the OSHA 300-A form, or by signing and dating a separate certification statement and appending it to the OSHA Form 300-A.

The requirement in Section 1904.32(a)(4) to post the Annual Summary also means that the certification must be posted in the workplace. In other words, if an employer chooses to certify the Annual Summary for an establishment by electronic signature, such certification must be printed and posted in the workplace from February 1 through April 30 of the year following the year covered by the OSHA Form 300-A.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep appraised of such developments, you can consult OSHA's website at http://www.osha.gov.


Keith Goddard, Director
Directorate of Evaluation and Analysis

Standard Interpretations - Table of Contents

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