OSHA Finalizes Dec. 15 as Electronic Recordkeeping Submissions Deadline


The federal Occupational Safety and Health Administration (OSHA) has finalized December 15, 2017 as the date by which certain employers are required to electronically submit data from their 2016 Forms 300A to OSHA.

Who Must Comply?
By December 15, 2017, the following establishments—if currently required to comply with OSHA’s recordkeeping requirements—are required to electronically submit data from their 2016 Forms 300A to OSHA:

However, according to OSHA, establishments in California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming are not yet required to submit data. Establishments located in these and other OSHA “State Plan” states should check with their states for the latest requirements.

Where Do I Submit the Data?
Covered establishments must submit the required data through OSHA’s online Injury Tracking Application.

Original Article – OSHA Proposes 5-Month Delay to Electronic Recordkeeping Submission Deadline

The federal Occupational Safety and Health Administration (OSHA) has issued a proposed rule seeking to extend the date by which certain employers are required to electronically submit the information from their completed 2016 Forms 300A. The proposed rule would change the submission date from July 1, 2017, to December 1, 2017.

OSHA also intends to launch its electronic data collection system by August 1, 2017. Previously, the agency announced it would not begin accepting electronic submissions prior to July 1, 2017.

Click here to read the proposed rule.

Background
In 2016, OSHA published a final rule, generally effective as of January 1, 2017, which requires certain employers to electronically submit injury and illness data to the agency as follows:

  • Establishments with 250 or more employees in industries covered by the recordkeeping regulation were to submit information from their 2016 Forms 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with 20-249 employees in certain high-risk industries were to submit information from their 2016 Forms 300A by July 1, 2017, and their 2017 Forms 300A by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA (however, employers with more than 10 employees and whose establishments are not classified as a partially exempt industry must otherwise comply with applicable OSHA recordkeeping provisions).

Note: Establishments located in OSHA “State Plan” states should check with their state plans for the implementation date of the new requirements.

Below is the table of “high risk” industries that must keep and submit records using form 300A:

Establishments in the following industries with 20 to 249 employees must submit injury and illness summary (Form 300A) data to OSHA electronically
NAICS Industry
11 Agriculture, forestry, fishing and hunting
22 Utilities
23 Construction
31-33 Manufacturing
42 Wholesale trade
4413 Automotive parts, accessories, and tire stores
4421 Furniture stores
4422 Home furnishings stores
4441 Building material and supplies dealers
4442 Lawn and garden equipment and supplies stores
4451 Grocery stores
4452 Specialty food stores
4521 Department stores
4529 Other general merchandise stores
4533 Used merchandise stores
4542 Vending machine operators
4543 Direct selling establishments
4811 Scheduled air transportation
4841 General freight trucking
4842 Specialized freight trucking
4851 Urban transit systems
4852 Interurban and rural bus transportation
4853 Taxi and limousine service
4854 School and employee bus transportation
4855 Charter bus industry
4859 Other transit and ground passenger transportation
4871 Scenic and sightseeing transportation, land
4881 Support activities for air transportation
4882 Support activities for rail transportation
4883 Support activities for water transportation
4884 Support activities for road transportation
4889 Other support activities for transportation
4911 Postal service
4921 Couriers and express delivery services
4922 Local messengers and local delivery
4931 Warehousing and storage
5152 Cable and other subscription programming
5311 Lessors of real estate
5321 Automotive equipment rental and leasing
5322 Consumer goods rental
5323 General rental centers
5617 Services to buildings and dwellings
5621 Waste collection
5622 Waste treatment and disposal
5629 Remediation and other waste management services
6219 Other ambulatory health care services
6221 General medical and surgical hospitals
6222 Psychiatric and substance abuse hospitals
6223 Specialty (except psychiatric and substance abuse) hospitals
6231 Nursing care facilities
6232 Residential mental retardation, mental health and substance abuse facilities
6233 Community care facilities for the elderly
6239 Other residential care facilities
6242 Community food and housing, and emergency and other relief services
6243 Vocational rehabilitation services
7111 Performing arts companies
7112 Spectator sports
7121 Museums, historical sites, and similar institutions
7131 Amusement parks and arcades
7132 Gambling industries
7211 Traveler accommodation
7212 RV (recreational vehicle) parks and recreational camps
7213 Rooming and boarding houses
7223 Special food services
8113 Commercial and industrial machinery and equipment (except automotive and electronic) repair and
maintenance
8123 Dry-cleaning and laundry services

Download OSHA Form 300A here