Update to OSHA Electronic Recordkeeping Deadline

Under a final rule that was deemed effective on January 1, 2017, the Occupational Safety and Health Administration (OSHA) announced its intent to update employer requirements for injury and illness data recordkeeping through required electronic submissions. While this information should continue to be kept on-site by employers, electronic submissions are intended to keep workers safer and make employers, the public and the government better informed about specific workplace hazards.

The initial submission deadline for 2016 Form 300A data (previously July 1, 2017) has been extended to December 1, 2017. Employers will be granted access to an electronic reporting system titled the Injury Tracking Application (ITA) on August 1, 2017 and will have until December to get familiar with the new system and upload 2017 300A data.

Electronic submissions can be presented in one of three ways through the ITA:

  • Data can be entered manually, through use of the online form.
  • Data can be uploaded via CSV files, representing a single establishment, or multiple locations simultaneously.
  • Data can be transferred through electronic transmissions, via the use of an API (Application Programming Interface) for users with access to automated recordkeeping systems.

According to OSHA.gov, the regulations require that “establishments with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from OSHA Forms 300 — Log of Work-Related Injuries and Illnesses, 300A — Summary of Work-Related Injuries and Illnesses, and 301 — Injury and Illness Incident Report. Additionally, establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses must electronically submit information from OSHA Form 300A.”

Updates on this topic can be found at www.osha.gov/recordkeeping.

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