The Occupational Safety and Health Administration (OSHA) has officially launched its Injury Tracking Application website for Electronic Submission of Injury and Illness Records to OSHA. The website launch has been much anticipated following the Trump Administration’s delay of the compliance deadline in the 2016 rule titled “Improve Tracking of Workplace Injuries and Illnesses” (the Electronic Reporting Rule). As we previously reported on this blog, the Obama-era Electronic Reporting Rule required employers to submit injury and illness logs electronically, and the original compliance deadline was July 1, 2017. In June, OSHA extend the initial submission deadline for 2016 Form 300A data to December 1, 2017, to provide the new administration an opportunity to review the new electronic reporting requirements prior to their implementation and allow affected entities sufficient time to familiarize themselves with the new electronic reporting system.
Under the Electronic Reporting Rule, 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). 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.
Under OSHA’s proposed rule to extend the compliance deadline in the electronic reporting rule, all covered establishments must submit information from their completed 2016 Form 300A by December 1, 2017. In 2018, covered establishments with 250 or more employees must submit information from all completed 2017 forms (300A, 300, and 301) by July 1, 2018, and covered establishments with 20-249 employees must submit information from their completed 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.
OSHA has now activated a secure website that offers three options for data submission. First, users can manually enter data into a web form. Second, users will be able to upload a CSV file to process single or multiple establishments at the same time. Last, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface).
OSHA’s website provides additional guidance and answers some FAQs on the new electronic reporting requirements.