HR Alert

OSHA Proposes 5-Month Delay to Electronic Recordkeeping Submission Deadline

Electronic Data Collection System to Launch by August 1, 2017

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 "<span>State Plan states"<https://www.osha.gov/dcsp/osp/> should check with their state plans for the implementation date of the new requirements.

For more information on OSHA's recordkeeping requirements, check out our Safety & Wellness section.


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