OSHA Is Accepting Electronic Injury and Illness Records Through Dec. 31


Lisa Nagele-Piazza, J.D., SHRM-SCP By Lisa Nagele-Piazza, J.D., SHRM-SCP December 19, 2017
OSHA Is Accepting Electronic Injury and Illness Records Through Dec. 31

The Occupational Safety and Health Administration (OSHA) announced on Dec. 18 that it will be accepting electronically submitted injury and illness reports through the end of the year.

The deadline for certain employers to file 2016 OSHA Form 300A data through the Injury Tracking Application (ITA) was Dec. 15, but the agency will not take enforcement action until Jan. 1, 2018, according to the announcement. OSHA will no longer accept 2016 data in the new year.

Form 300A is a summary of workplace injuries and illnesses that covered employers are already required to post in the workplace from Feb. 1 until April 30 of each year. Certain employers were required to electronically submit this data from their 2016 Form 300A by Dec. 15.

Eventually, large employers will also have to electronically submit data from Form 300 (the injury and illness log) and Form 301 (incident reports for each injury or illness).

The first compliance deadline was extended several times in 2017 in order to give the agency time to get the ITA up and running and to allow the Trump administration more time to evaluate the rule, said Patrick Miller, an attorney with Sherman & Howard in Denver, in an interview with SHRM Online in August when the portal was launched.

Submitting Data

The Dec. 15 deadline applied to businesses that are covered by OSHA's record-keeping regulations and have 250 or more employees, as well as covered establishments with 20-249 employees in certain hazardous industries.

 [SHRM members-only how-to guide: How to complete OSHA Form 300]

The data submission process involves four steps:

  • Creating an establishment within the ITA.
  • Adding 300A summary data.
  • Submitting data to OSHA.
  • Reviewing the confirmation e-mail.

The website offers three options for data submission. Employers can:

  • Manually enter data into a web form.
  • Upload a file for a single establishment or for multiple establishments at once.
  • Transmit data electronically through an application programming interface—if the employer uses an automated record-keeping system.

The electronic record-keeping rule also prohibits employers from retaliating against workers who report injuries. These so-called anti-retaliation provisions—which went into effect in December 2016—place limitations on safety incentive programs and drug-testing policies that the agency says may deter workers from reporting incidents.

Businesses should comply with all aspects of the rule that affect their workplace. Though, employers should note that the Trump administration may take a new look at the rule. "It is anticipated that OSHA will propose additional changes to this rule in the near future and OSHA will issue another Notice of Proposed Rulemaking in the Federal Register next year," according to Tressi L. Cordaro, an attorney with Jackson Lewis in Washington, D.C.


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