The Occupational Safety and Health Administration's (OSHA) new electronic record keeping rule requires certain employers to electronically submit to OSHA the injury and illness information that they are already required to keep under existing regulations.
Who does this rule affect?
Companies with 250 or more employees that are currently required to keep injury and illness records.
Companies with 20 or more employees but fewer than 250 employees in certain high risk industries. These industries include construction, manufacturing, utilities, retail, transportation, healthcare and more.
OSHA may request injury and illness information from companies that are not required to submit injury and illness information to OSHA on a routine basis. If such request is received the company would be required to submit requested information.
By July 1, 2017, all employers required to submit electronic records must submit their annual Summary of Work-Related Injuries and Illnesses (Form 300A) to OSHA.
On July 1, 2018, companies with 250 or more employees must submit Log of Work-Related Injuries and Illnesses (Form 300), Injury and Incident Report (Form 301) and Form 300A. Companies with 20-249 employees will continue to submit only Form 300A.
Beginning in 2019, the submission deadline will change from July 1 to March 2.
States are required to enforce substantially similar regulations within six months of the rules publication.
What should companies do now?
Train employees on the requirements of the new rule and when it goes into effect.
Ensure that employees understand that they will not be retaliated against for reporting work-related injuries and illnesses and are encouraged to report them.
Retrain employee(s) responsible for injury and illness record keeping on the basics for record keeping and provide thorough training on the new rules with an emphasis on protecting personally identifiable information to the maximum extent possible while remaining in compliance with the new regulatory requirements.
Review and revise drug testing policies to bring them into compliance with the requirements of these rules.
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