For decades, OSHA has required employers to keep track of their employees’ injuries and illnesses by recording them in what’s commonly referred to as an “OSHA log.” However, the agency recently released a final rule that will also require some employers to submit these records electronically to be posted on OSHA’s website.
Purpose of the Final Rule
OSHA believes that publishing injury and illness data electronically will help inform employers, the general public and the government about workplace hazards. Additionally, OSHA believes the new rule will do the following:
- Encourage employers to increase their efforts to prevent worker injuries and illnesses, and compete with their peers to promote employee safety.
- Enable researchers to examine the data in innovative ways that may help employers make their workplaces safer and healthier.
The final rule also includes provisions to encourage workers to report work-related injuries or illnesses to their employers and to prohibit employers from retaliating against workers for making those reports.
Electronic Submission Requirements
The following are the requirements for the new rule:
- Establishments with 250 or more employees that are required to keep OSHA injury and illness records must electronically submit the following forms:
- OSHA Form 300: Log of Work-Related Injuries and Illnesses
- OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
- OSHA Form 301: Injury and Illness Incident Report
- Establishments with 20-249 employees that work in industries with historically high rates of occupational injuries and illness must electronically submit information from OSHA Form 300A.
The new rule will not change an employer’s requirements to complete and retain regular injury and illness records.
Data submission from OSHA Forms 300, 300A and 301 will be phased in as follows:
|Submission year||Establishments with 250
or more employees
|Establishments with 20-249 employees||Submission deadline|
|July 1, 2017|
|2018||Forms 300, 300A, 301||Form 300A||July 1, 2018|
Because OSHA believes the timeliness of the data collected is important for surveillance and intervention activities, the submission deadline will be changed from July 1 to March 2 beginning in 2019.
OSHA will post the establishment-specific injury and illness data it collects under this recordkeeping rule on its public website, www.osha.gov. The agency will also remove any personally identifiable information (PII) before the data is released to the public.
For additional resources, contact Odell Studner today. Our team of experts can provide you with our comprehensive Compliance Bulletin, “OSHA Issues Final Rule on Electronic Reporting.”