Covered employers need to electronically submit their 2017 Occupational Safety and Health Administration (OSHA) 300A summary of injuries and illnesses to OSHA by July 1, 2018 under OSHA’s electronic record keeping rule which took effect last year.
Summary of Requirements
WHO: Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.
WHAT: Covered establishments must electronically submit information from their 2017 OSHA Form 300A.
WHEN: In 2018, covered establishments must submit information from their completed 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.
HOW: OSHA will provide a secure website that offers three options for data submission.
- First, users will be able to manually enter data into a web form.
- Second, users will be able to upload a .CSV file to process single or multiple establishments at the same time.
- Last, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface).
Who Does Not Need to Electronically Report Data to OSHA?
Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to send their information to OSHA. The criteria apply at the establishment level, not to the organization as a whole.
- The establishment’s peak employment during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
- The establishment’s industry is on this exempt industries list, regardless of the size of the establishment.
- The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is NOT on this list of industries with 20 to 249 employees that must submit injury and illness summary (Form 300A) data to OSHA electronically.
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 comments on those provisions.
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