As we discussed last May, OSHA issued a final rule related to the collection of workplace injury and illness data. One aspect of this rule was the electronic submission of records. OSHA has recently shared their intent to propose a delay in the submission deadline.
According to the OSHA website, "OSHA is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically." When available, updates will be posted to the OSHA recordkeeping page.
The rule, which became effective on January 1, 2017, planned to phase in the recording requirements over two years. The original compliance schedule was as follows:
- Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
- Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
The July 1, 2017 dates are the deadlines currently in question. It is not yet clear what the new deadline will be and if any other aspects of the compliance schedule will be impacted. The delay has been discussed by many news sources - including Business Insurance, The National Law Review, and Safety & Health Magazine - but we still await an update from OSHA regarding the new compliance schedule.
Who is impacted by the recordkeeping rule? There are 2 groups who must comply:
- Organizations with 250 or more employees in industries covered by the recordkeeping regulation
- Organizations with 20-249 employees in certain high risk industries
Stay tuned for updates once more information is released from OSHA on this matter. If you have questions in the meantime, do not hesitate to reach out to me or another member of the loss prevention team.
