On January 1, 2017, OSHA officially put into effect a revision to workplace injury and illness reporting that requires certain employers to submit recorded information of these instances electronically. Companies were to submit all of this information from the previous year (2016) by July 1, 2017, but now that due date is in jeopardy.
OSHA’s recordkeeping website has recently been updated to include this note: “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.” No timeframe for when the electronic submissions will now be due has been released yet.
According to the new rule, companies with 250 or more employees were required to submit form 300A by July 1, 2017 with 2016 information. For their 2017 information, those same companies would be required to submit forms 300A, 300, and 301 by July 1, 2018.
For companies that have 20-249 employees and that are in high risk industries like construction, only form 300A will need to be filled out with the previous year’s information on July 1st every year.
Form 300A is a high level overview of injury and illness numbers for the previous year. Form 300 is a more in-depth log of injuries and illnesses that include names of the employees and other information. Form 301 is an incident report that includes more detail about individual injury/illness events. All 3 forms can be found by clicking here.
The National Association of Home Builders has been a strong opponent of the electronic record-keeping requirement. Shortly after the rule was made effective, the organization filed a challenge against OSHA, citing concerns of reputational harm to employers and an overreach of governmental authority.