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OSHA Reiterates July 1 Reporting Deadline

Friday, June 29, 2018

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The U.S. Department of Labor’s Occupational Safety and Health Administration is reminding employers that electronic injury and illness reports for some are due Sunday (July 1).

As part of the Improve Tracking of Workplace Injuries and Illnesses rule issued in 2016 and put into effect last year, employers with more than 250 employees, as well as those with between 20 and 249 employees that operate in certain high-risk industries like construction, must submit Form 300A summary data for 2017 electronically by the July 1 deadline.

OSHA website
© / ridofranz

OSHA requires some employers to electronically submit Form 300A injury and illness data for 2017 by Sunday, July 1.

The electronic-reporting rule, which was subject to a number of legal challenges and delays, requires employers to take data they already submit to OSHA and supply it electronically; the data is meant to be made publicly available, without any personally identifiable information about the workers involved in injury or illness incidents. The rule also includes a number of anti-retaliatory provisions, which went into effect in late 2016.

Rule History

The rollout of the Improve Tracking rule was slow coming, as implementation was delayed early on by a regulatory freeze called at the outset of President Donald J. Trump’s administration, and the data-submission website went online later than expected then was taken down temporarily over concerns of compromised user information.

The first deadline, for data covering 2016, came Dec. 31, 2017. The deadline for 2017 data comes as some state occupational-safety agencies have yet to adopt parallel rules for their states, leading to questions regarding whether employers in those states must comply.

State Plan Reaction

In April, OSHA issued a press release insisting that all employers fitting the description set forth in the rule must comply by July 1, regardless of whether their state plan has issued a rule of its own in accordance with the federal rule. Some states, including Washington and Wyoming, responded that employers under their jurisdiction were not required to comply because they had not issued a final state rule related to electronic reporting.

State plans are required to institute rules at least as strict as those issued by federal OSHA, but the Improve Tracking rule has changed several times and could still be subject to further changes via the rulemaking process, leading to some states’ reluctance to replicate the current rule. The rule as written requires businesses with more than 250 employees to electronically submit Form 300 and 301 data in addition to Form 300A summary data, but OSHA is only accepting Form 300A data electronically right now, and may change the rule to make that permanent.

Compliance with the Improve Tracking rule continues to roll out gradually; while business have until July 1 to submit 2017 data, they will only have through March 2, 2019, to submit 2018 data.

Injury and illness data can be submitted here.


Tagged categories: Government; Health and safety; OSHA; Regulations

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