Did You Electronically Submit Your OSHA Forms?
July 5, 2018 | Angela Snyder, Esq.
Under the current recordkeeping rule, the deadline for electronic submission of information from OSHA Forms 300 and 301 by covered establishments was July 1, 2018.
However, OSHA has announced its intent to issue a proposal to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees which are required to routinely keep injury and illness records.
OSHA will not enforce this deadline for these two forms without further notice while this rulemaking is underway.
All covered employers can continue to electronically report their Calendar Year (CY) 2017 Form 300A data to OSHA, submissions after July 1, 2018 will be flagged as “Late”.
Not sure whether you are a covered establishment? You aren’t alone.
There are two groups of “covered establishments” required to submit accident and injury reports to OSHA. Companies that have 250 or more employees that are currently required to keep OSHA injury and illness records, and companies with 20-249 employees that are classified in certain high risk industries. A list of high risk industries is located here: https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.html.
However, not all employers are required to keep OSHA injury and illness logs. Certain partially exempt industries are not required to keep OSHA injury and illness records regardless of their size. A list of partially exempt industries is located here: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html. These establishments are not required to keep OSHA accident and injury logs, and are not subject to OSHA’s electronic record keeping rules.
OSHA refers to these industries as “partially exempt” because these establishments must still report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye.
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