This article was updated to reflect OSHA's notice on November 22 that it has extended the date by which employers (who are regulated under the OSHA recordkeeping regulation) must electronically report injury and illness data through OSHA’s Injury Tracking Application (ITA) portal to December 15, 2017. OSHA noted that the slight extension of time (from the previous deadline of December 1) is to allow affected employers additional time to become familiar with a new electronic reporting system launched this past summer.
Although the ultimate fate of certain provisions in OSHA’s electronic reporting regulation has not yet been decided, there are just a few weeks remaining before the December 15 deadline for certain employers to file their 2016 form 300A with OSHA, using the electronic portal found at its website.
The OSHA website provides a detailed description of covered employers, compliance dates and electronic portal instructions. But, here are the general guidelines:
Establishments with 250 or more employees in industries covered by OSHA’s recordkeeping regulation must electronically submit information from their 2016 Form 300A by December 15, 2017. These same employers will be required to electronically 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 electronically submitted by March 2 of each year.
Establishments with 20-249 employees in certain high-risk industries must electronically submit information from their 2016 Form 300A by December 15, 2017 and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information 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.
The new regulation does not change the manner in which employers are to collect/record occupational injury and illness information. It does require, however, electronic submission of the forms noted above, by the currently effective compliance deadlines.
OSHA advised that employers in California, Maryland, Minnesota, South Carolina, Utah, Washington and Wyoming are not currently required to submit their summary data through the ITA because those OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically.
If we learn of any changes or further postponements to the deadlines, we will issue a further alert.