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OSHA Electronic Reporting Requirement

- December 11, 2017 by Rick Fineman, CSP, ARM (View all posts by Rick)

In 2016, OSHA issued a final rule regarding the tracking and reporting of workplace injuries. Electronic submission — rather than paper submission — of injury and illness data, also known as the Log 300, will be required. Covered employers with 250 or more employees at an establishment will be required to electronically submit the OSHA Form 300300A and 301.  Certain smaller employers in industries with high rates of injuries and illnesses will be required to electronically submit the OSHA Form 300A.

The Federal electronic reporting requirements will be phased in over a two-year period. Initial Federal reporting requirements set for July 1 of this year were moved to December 15, 2017, and the current Federal administration is also reviewing the final rule.

Employers who fall under Electronic Reporting guidelines can use the updated Injury Tracking Application for electronic reporting.

California Employers

If you are a California employer trying to determine if you have to follow the electronic reporting required under the new Federal electronic reporting requirements, the short answer is no.

At this time, California employers do not need to follow the Federal requirements.

So what does all of this mean for employers who are governed by California’s Division of Occupational Safety and Health, better known as Cal/OSHA?

Federal OSHA has given states that operate their own safety and health programs, such as California, extra time to implement the new requirements. The Federal compliance dates do not apply to California employers.

According to Cal/OSHA, California employers are not required to follow the new Federal requirements and will not be required to do so until “substantially similar” state regulations go through the formal rulemaking, adoption and approval process.  “California employers are not affected by the Federal OSHA extension date because the new requirements have not yet been adopted or approved in California,” said Department of Industrial Relations Public Information Officer Frank Polizzi to the Cal-OSHA reporter.

Cal/OSHA drafted a proposed rulemaking package to conform to the revised federal OSHA regulations. The package is being reviewed internally before the formal rulemaking process and public comment period begins.

Until Cal/OSHA implements the Federal changes in California, the Federal rules will not be enforced. Employers should be on the lookout for California’s implementation of these Federal rules.

If you have operations outside of the state of California, all employers will be required to report electronically.  This will be phased in with employers with over 250 employees starting in 2018.

In addition, certain industries will be required to comply with the requirements at a lower employee threshold (25 to 250 employees).

*Note -the following OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY. Establishments in these states are not currently required to submit their summary data through the ITA. Similarly, state and local government establishments in IL, ME, NJ, and NY are not currently required to submit their data through the ITA.

Contact information for each of the State Plans can be found at: https://www.osha.gov/dcsp/osp/index.html