3 Things You Need to Know About OSHA’s Electronic Submission

 

On May 31, 2016, we published this article explaining the requirements under OSHA’s New Final Rule on Recordkeeping for recording and reporting workplace injuries and illness. Now, employers are not only subject to keep logs of any and all workplace injuries, but to electronically submit those logs. As stated in the previously mentioned blog post, “The hope is that through the public disclosure of workplace safety data for individual employers, those with high injury incidence and lagging safety processes will be naturally “encouraged” to make improvements.” Initially, OSHA’s website for electronic submissions was set to open on July 1, 2017. However, changes have been made since then…

 

3 Things You Need to Know About OSHA’s Electronic Submission

 

  1. Compliance Deadline Has Been Pushed to December 1, 2017

On June 27th, just five days before the intended compliance date, OSHA published a National News Release stating that OSHA “proposed a delay in the electronic reporting compliance date… from July 1,2017 to December 1, 2017. The proposed delay will allow OSHA an opportunity to further review and consider the rule.” OSHA now has longer to prepare for the impending compliance with electronic submissions, as well as employers.

 

  1. Web-Based Injury Tracking Application (ITA) Will Launch August 1, 2017

In a Trade Release on July 14, 2017, OSHA announced the application for submitting injury and illness data will be available on August 1, 2017. However, you do not need to submit data immediately. Employers will need to complete their 2016 OSHA Form 300A and submit by December 1, as things currently stand. In 2017, the only form required is the 300A, however, as shown in the table below, additional forms will be required in coming years.

Submission Year Establishments with 250 or more employees Establishments with 20-249 employees Submission deadline
2017 Form 300A Form 300A July 1, 2017
2018 Forms 300A, 300 & 301 Form 300A July 1, 2018
2019 & on Forms 300A, 300 & 301 Form 300A March 2nd
  1. Possibilities of New Secretary of Labor for OSHA Before Compliance Deadline

Former Assistant Secretary of Labor at OSHA, Edwin G. Foulke Jr., has stated a new secretary of labor will likely be nominated and confirmed as early as September. In an article from EHSToday summarizing Mr. Foulke’s statement, they write “he is suggesting to clients to wait a few months until the new OSHA administrator is in office and challenges to the publication of injury and illness data to OSHA’s website have been settled before posting their injury and illness data.” Drew Page, OSM’s Director of Operations, stated, “I… think it is smart to hold off until November to submit but even smarter to ensure the info is accurate NOW.”   Regardless of when compliance for electronic submissions will officially take effect, reviewing logs and preparing for enforcement now can only put you in a better situation later. As always, our safety professionals are here to help you understand and move forward with clarity. Our Safety Helpline is open for questions! Feel free to contact us today!

 

888-707-2338 or SafetyHelpline@Optimum-USA.com

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