June 28, 2018

On the Horizon: OSHA's July 1 Electronic Filing Deadline Nears

As previously noted in a November alert, another deadline for OSHA filings approaches -- and while the ultimate fate of certain provisions in OSHA’s electronic reporting regulation is still in limbo -- employers should remember that there are just a few days left to file certain 2017 forms using OSHA’s electronic portal.

OSHA’s website provides a detailed description of covered employers, compliance dates and electronic portal instructions. But, here are a few general guidelines:

Establishments with 250 or more employees in industries covered by OSHA’s recordkeeping regulation are required to electronically submit information only from their 2017 form 300A by July 1, 2018. OSHA is not currently accepting information for Form 300 or 301. Beginning in 2019 and every year thereafter, the information required by OSHA must be electronically submitted by March 2 of each year.

Establishments with 20-249 employees in certain high-risk industries must also electronically submit information from their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information required by OSHA must be electronically submitted by March 2 of each year. The list of such “high-risk” industries, categorized by NAICS number can be found at OSHA’s website.

Please note that, as announced by OSHA, 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. OSHA notes on its website that it is currently drafting that NPRM and will seek comment on it.

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