This week we continue our dive into OSHA recordkeeping and filing as the March 2 OSHA filing deadline draws near.
We recently hosted a webinar discussing OSHA Compliance Update for 2023 with Dustin Boss who shared a wealth of important information for attendees looking to make sure they have all of their OSHA recordkeeping ducks in a row.
While there was too much information to cover in one blog post, we’ve highlighted some of the key takeaways you will want to be aware of.
1. THERE'S A NEW SHERIFF IN TOWN
As part of his campaign and now in his administration, President Biden has placed much emphasis on labor and OSHA. The administration has indicated that it wants to increase both enforcement and recordkeeping. Plans include doubling the number of inspectors and requiring companies to provide more data than in the past.
According to a March 2022 press release, the agency is proposing that companies with 100 or more employees in certain high-risk industries must submit not only their 300A reporting document annually but also their Forms 300 and 301.
We’ll be anxiously awaiting the final rule as its impact could be significant.
2. KEEPING COUNT
When it comes to who needs to file their annual log to OSHA, the rules are pretty clear. Unless requested by OSHA or the Bureau of Labor Statistic, the requirements are:
A company with 10 or fewer employees in a preceding year does not need to keep records or file.
A company with between 11-19 employees, needs to keep records, but not file.
A company with between 20-249 employees in a high-risk industry (and OSHA considers 2/3 of industries to be “high risk”) needs to keep records and file electronically.
And a company with 250 or more employees, regardless of industry, needs to keep records and electronically file.
But counting employees can be tricky when one takes into account part-time employees, contract workers, seasonal workers and temps. For the most part, they all count toward a company’s headcount.
The rule of thumb is that, if at any point in the year you had more than a threshold (more than 10; more than 19…) then you would be subject to the recordkeeping requirements of that higher number of employees. There are a few exceptions, but if you’re ever in doubt about how to count the totality of your workforce in a given year, you can reach out to our team for help.
3. WHAT TO DO RIGHT NOW
With a few weeks life before reporting is due, it’s time now to identify and find any missing data that you’ll need.
It’s also a good time to correct the record on previous years’ logs if you come across any.
While all of this recordkeeping may seem like a headache, it is critical to keep it all in order. It’s important for internal purposes, to help prevent future injuries and incidents but it will also help you in the event of an OSHA inspection.
A company whose recordkeeping is thorough, organized and easily accessible may signal to an OSHA inspector that they take safety seriously and likely have other aspects of their operation buttoned-up as well.
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