RISK INSIGHT: OSHA Form 300A Electronic Submission Reminder

OSHA Electronic Reporting Rule Update – ALL Submissions due July 1, 2018

In 2016, the Occupational Safety and Health Administration (OSHA) issued a final rule requiring employers to report workplace injury and illness data electronically to OSHA.  After several delays, OSHA recently announced that all establishments affected by the rule must submit 2017 data by July 1, 2018.  This includes establishments in states that have incorporated the electronic reporting rule into its OSHA state plan. OSHA defines an establishment as a single physical location where business is conducted or where services or industrial operations are performed.

The 2016 electronic reporting requirement applies to a specific establishment in the following situations:

  • The establishment is already required to create and maintain OSHA injury and illness records AND has 250 or more employees OR
  • The establishment has between 20 and 49 employees and belongs to a high-risk industry; OR
  • The establishment receives a specific request from OSHA to create, maintain and submit electronic records, even if they would otherwise be exempt from OSHA recordkeeping requirements.

It is important to note that the electronic reporting rule applies to establishments and not employers as a whole. Employers may have several worksites or establishments, some which may be affected by the rule while others are not.  Employers must determine whether or not they are affected by determining each establishment’s peak employment during the calendar year by counting every individual that worked at the establishment, regardless of full-time, part-time, temporary or seasonal status.

Establishments in ALL states must submit 2017 data by July 1, 2018.  States with OSHA approved state plans (All employers – CA, MD, MN, SC, UT, WA, WY; Public employers – IL, ME, NJ, NY) were not required to submit 2016 data (due by December 31, 2017) but must now submit 2017 data by July 1, 2018.

In order to meet the July 1 deadline, employers should:

  • Understand the rules: Employers can familiarize themselves with the electronic reporting requirements (more information available at osha.gov/recordkeeping); and
  • Online records: If you have not yet transitioned to electronic records, OSHA has detailed instructions on how you can submit your records electronically via the Injury Tracking Application page on their website.

Key Takeaway: 

Employers should have a firm understanding of the finalized OSHA electronic reporting rules, regardless of their state of operations.  It is important to file prior to the July 1 deadline to meet your legal obligations and avoid federal penalties for failing to report.

If you need additional assistance, have questions about OSHA recordkeeping please feel free to contact your M3 Account Executive or Risk Manager for more information.

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