OSHA Amends Electronic Record Rules

By Robert G. Chadwick, Jr., Managing Member, Seltzer, Chadwick, Soefje & Ladik, PLLC.

As reported in a previous post on this blog, OSHA published on May 12, 2016 a final rule amending its record-keeping regulations to include new electronic submission mandates. The 2016 rule requires that establishments with 250 or more employees electronically submit injury and illness data they are already required to record on their onsite OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 301 (Injury and Illness Incident Report) and 300A (Summary of Work-Related Injuries and Illnesses). The 2016 rule further mandates that, for 66 classified industries,  an establishment with 20-249 employees electronically submit its OSHA Form 300A.

On January 24, 2019, OSHA published a new final rule which amends the previous 2016  rule effective February 25, 2019 in two respects.

First,  establishments with 250 or more employees are no longer required to electronically submit information from OSHA Forms 300 and 301. Such employers are still required to electronically submit information from OSHA Form 300A.

Second, each establishment required to electronically submit its OSHA Form 300A must include its Employer Identification Number with the submission.

As with the 2016 rule, the new rule does not alter an employer’s duty to maintain OSHA Forms 300, 301 and 300A on-site, and OSHA will continue to obtain these forms as needed through inspections and enforcement actions.

Collection of Calendar Year 2018 information from the OSHA Form 300A began on January 2, 2019. The deadline for electronic submissions is March 2, 2019.

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