NEW OSHA RULE: Electronic Submissions Now Mandatory for Certain Employers

OSHA RecordkeepingA new OSHA rule is requiring certain employers to start electronically submitting their recordkeeping forms on workplace illnesses and injuries to OSHA.

Currently, employers who are required by OSHA to complete the 301, 300 and 300A recordkeeping forms were only required to produce the forms when requested by OSHA as part of an inspection or investigation.  Some employers would receive a survey from the Bureau of Labor to answer questions regarding information on their 300 and 300A forms, but were never asked to submit the actual forms.

OSHA will require employers with 250 or more employees who are already required to complete the recordkeeping forms to submit the forms electronically. This information will then be posted on OSHA’s website.  In addition to large employers mentioned above, employers of certain industries will be required to submit the 300A form only.  Below is a link to OSHA’s website regarding the new rule.  The website gives a list of industries under 250 employees who will be required to submit their 300A forms along with FAQ’s.

Although the new rule goes into effect in August of 2016, data submissions will be phased in starting in January 2017.  In 2017, large employers of 250 employees or more, along with certain industries, must submit their 300A form to OSHA by July 1, 2017.  In 2018, large employers will be required to submit the 301, 300 and 300A forms by July 1, 2018 and selected industries will have the same deadline, but will only be required to submit the 300A form.  In 2019, the submission deadline will change from July 1st to March 2nd.  OSHA plans to provide a secure site to which employers can submit their forms.  Personally identifiable information will be removed from the data before being posted on the OSHA website.

The new rule does not change the current recordkeeping rule.  Employers already required to complete the form should continue to do so and keep them for the mandatory 5 years.

Please contact your W3 advisor with any questions regarding OSHA’s new rule and if you are in the list of industries required to submit.