Workplace Injury Recordkeeping

Effective July 2, 2018, implementation of “Improve Tracking of Workplace Injuries and Illness” Regulation goes into effect and how you track Workplace Injury Recordkeeping will change.

What does this mean for your company? Depending on the size of your company and the NAICS code you fall under, you will be required to electronically submit all injury and illness data that is already required on the OSHA Injury and Illness forms (typically referred to as the OSHA 300 Log).

What does the rule require?

The new rule, which takes effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. Analysis of this data will enable OSHA to use its enforcement and compliance assistance resources more efficiently. Some of the data will also be posted to the OSHA website. OSHA believes that public disclosure will encourage employers to improve workplace safety and provide valuable information to workers, job seekers, customers, researchers and the general public. The amount of data submitted will vary depending on the size of company and type of industry.

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2017 Form 300A by July 1, 2018. 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 2017 Form 300A by July 18, 2018.

Employers can now begin to electronically report their Calendar Year (CY) 2017 Form 300A data to OSHA. All covered establishments must submit the information by July 1, 2018. Employers can view their submitted CY 2016 Form 300A summary information, but they cannot edit or submit additional 2016 data on this website. Remember, not all establishments are covered by this requirement.

Covered establishments with 250 or more employees are only required to provide their 2017 Form 300A summary data. OSHA is not accepting Form 300 and 301 information at this time. OSHA announced that it will issue a notice of proposed rulemaking (NPRM) to reconsider, revise, or remove provisions of the “Improve Tracking of Workplace Injuries and Illnesses” final rule, including the collection of the Forms 300/301 data. The Agency is currently drafting that NPRM and will seek comment on those provisions.

For more information: https://www.osha.gov/recordkeeping/finalrule/