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OSHA’s New Recordkeeping Rule Part 1

- January 19, 2017 by Philip Bivens, CSP (View all posts by Philip)

Did you know the Occupational Safety and Health Administration (OSHA) issued a final rule that calls for some employers to electronically submit their injury and illness data?  The rule was created in efforts to   improve the safety of US workers by ‘nudging’ employers to prevent work injuries to show investors, job seekers, customers and the public they operate safe and well-managed facilities. OSHA believes the more attention to safety will not only save the lives of workers but also ultimately improve the bottom line for employers. Accuracy of the data will also be improved as workers will not fear retaliation for reporting injuries and illnesses.

Requirements

The new rule took effect on January 1, 2017.  OSHA plans to analyze the data collected and use it to improve its enforcement and compliance assistance resources more efficiently. OSHA also plans to post some of the data on their website. The data amount that is required to be submitted will vary of the size of the company and the type of industry.

Implementation

OSHA will provide a secure website that offers three data submission options: manually enter data into a webform; upload a CSV file to process single or multiple establishments at the same time; or transmit data electronically via an API (application programming interface) if using an automated recordkeeping systems. The site is scheduled to go live in February.

Timeline

The timeframe for implementation for this new rule will be phased in over two years. Companies 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.

For more information on OSHA’s injury and illness recordkeeping and reporting requirements, visit here.

 

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