OSHA has scaled back the number of forms larger employers have to submit electronically. However, there is something new employers now have to submit.
The revised OSHA recordkeeping rule eliminates the requirement for facilities with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Report) each year.
These facilities are still required to electronically submit information from OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).
Facilities are still required to maintain Forms 300 and 301 on-site. OSHA will continue to obtain these forms as needed through inspections and enforcement.
OSHA says by revising the rule, it’s avoiding the risk that facts about employees might be publicly disclosed under Freedom of Information Act requests.
OSHA will continue to use information from severe injury reports and Form 300A to focus its enforcement and compliance assistance.
Employers covered by the rule can electronically submit their 300A Summary anytime now. The deadline is March 2, 2019.
Some smaller facilities, too
In summary, these facilities still have to file Form 300A to OSHA no later than March 2:
- Facilities with 250 or more employees that are currently required to keep OSHA injury and illness records, and
- Facilities with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.
A new requirement
Included in this revision is one new requirement, but it’s not a large one.
Covered employers are now required to electronically submit their Employer Identification Number (EIN) with their Form 300A. This will make the data more useful to OSHA and the Bureau of Labor Statistics, which tabulates an annual summary of U.S. employee injuries and fatalities.
A reminder: This rule also prohibits employers from retaliating against workers for reporting injuries and illnesses.
