Time to make sure your company is compliant with the latest recordkeeping requirements.

The new rule, effective January 1, 2017, requires certain employers to submit injury and illness data electronically.

This blog, originally posted May 19, 2016, has been updated with additional sources and information.

Final Recordkeeping Rule

As you know, OSHA already requires many employers to keep a record of injuries and illnesses. This data can then be used to identify hazards and prevent additional injuries and illnesses in the workplace.

On May 11, 2016, OSHA issued a final rule to these requirements, which will help modernize injury data collection by requiring employers in certain industries to electronically submit injury and illness data to OSHA instead of using paper logs.

What else do you need to know about the final recordkeeping rule?

  • Effective date for this rule is January 1, 2017.
  • OSHA intends to post this data on a publicly accessible website.
  • Anti-retaliation protections for employees are included.

A press release dated May 11, 2016 stated that, “just as public disclosure of their kitchens’ sanitary conditions encourages restaurant owners to improve food safety, OSHA expects that public disclosure of work injury data will encourage employers to increase their efforts to prevent work-related injuries and illnesses.”

Two-year Phase in of Reporting Requirements

Under the new rule, all establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms – 300A, 300 and 301 – by July 1, 2018. Beginning in 2019, the information must be submitted by March 2 every year.

Establishments with 20-249 employees in certain high-risk industries must electronically submit information from their 2016 Form 300A by July 1, 2017 and their 2017 Form 300A by July 1, 2018. Beginning in 2019, the information must be submitted by March 2nd every year.

Options for Submission of Data

Starting in February 2017, there will be three options for submission of injury data.

  • Data can be entered manually through a secure web form
  • A CSV file can be uploaded to process a single or multiple establishment once
  • If an automated recordkeeping system is used, you can transmit data via an API

Benefits of the New Rule

  • OSHA will be able to quickly analyze the data and be more efficient in its regional enforcement and compliance.
  • Injury information submitted electronically will be publicly available, which puts a focus on unsafe workplaces.
  • The anti-retaliation protection should help to improve the accuracy of the data.

Recordkeeping Rule Sources of Information

OSHA provides several resources to help educate employers about this requirement.