Safety and OSHA News

OSHA delays new recordkeeping rule

Larger employers and those in certain high-risk industries that were supposed to electronically submit injury records to OSHA by July 1 will get a break from that deadline. 

On OSHA’s Injury and Illness Recordkeeping and Reporting Requirements webpage, an update has been added that states:

“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. Updates will be posted to this webpage when they are available.”

The National Law Review reports OSHA sent an email to stakeholders which stated:

“OSHA intends to extend the initial date by which certain employers are required to electronically submit their injury and illness logs. The Recordkeeping Rule currently requires certain employers to submit the information from their completed 2016 Form 300A to OSHA electronically by July 1, 2017. The proposal will extend this to a later date. Currently, we do not have any additional information about the timeline for this. We will let you know as additional information, including a proposed extension date, is available.”

The new rule requires certain employers under federal OSHA jurisdiction to electronically submit injury and illness data that they are already required to record on their onsite OSHA injury and illness forms:

  • Employers with 250 or more employees in industries covered by OSHA’s recordkeeping regulation were scheduled to 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.
  • Employers with 20-249 employees in certain high-risk industries were scheduled to 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.
  • OSHA State Plans must adopt requirements that are substantially identical to the requirements in this rule.
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Comments

  1. I think we saw this coming. From what I recall, the website had not been built that would allow data to be submitted. I’m sure it will still happen. Makes sense to submit it electronically. Should keep costs down as long as OSHA doesn’t spend millions making it happen.

  2. Federal agencies submitted the full set of data last year and again this year. The submission included a line for each establishment within the agency with the 18 data points from the 300A, and a detail case file with a line for each recordable injury including 25 data items from the 301 or equivalent report. The format was a simple comma delimited file (.csv flat file) that anyone can produce from an MS Excel spreadsheet. For an agency with 50,000+ employees and 451 establishments, the summary file was (no brainer here) 451 lines of data, 1 for each 300A, and the detail case file was about 1300 lines long, one for each recordable injury. Our agency is considerably bigger than the typical employer that would have been required to submit these, but our rates are not particularly high. Because we use a fairly robust electronic SMS this data pull is not a real heavy lift. Our injury reports go through a fairly detailed quality assurance process so it only takes one person to pull the annual data together, correct any errors missed in the QA process, and produce files in compliance with the BLS requirements.
    I really have not problem providing this data to OSHA/BLS. We try to focus on injury prevention through hazard identification and elimination, training and other means, but if OSHA/BLS can identify a trend out of our raw injury data that we missed and focus enforcement efforts on that, it really does us no harm. As for the privacy concerns, these are the same folks who have access to our workers’ compensation files, and are required to protect this data under the same privacy controls, so I am not particularly concerned.

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