OSHA just released a revision to their 29 CFR 1904 Recordkeeping Rule. This revision will now require many companies to report their “Recordable” injuries to OSHA electronically each year. Here are some quick bullet points that summarize the key highlights of this change…
- All companies with 250 or more employees (at any one time the previous calendar year) will be required to submit data electronically each year from their OSHA 300A, 300, and 301 forms. This requirement will be phased in by only requiring the 300A to be submitted by July 1, 2017; then requiring all forms to be submitted the next year by July 1, 2018; and finally submitting all forms for the following year and every year thereafter by March 2.
- Companies with 25-249 employees (at any one time the previous calendar year) will be required to submit data electronically each year from their OSHA 300A (not the OSHA 300 or 301), BUT ONLY IF they are in certain industries specified by OSHA. Click here for a complete list of affected industries. This reporting will be due by July 1 in 2017 and 2018 but will change to March 2 in 2019.
- This will not change any of the existing obligations to maintain OSHA Logs. It will simply take the place of the annual survey that is randomly circulated by the Bureau of Labor Statistics.
- OSHA will provide a secure website for employers to use when logging this data.
- There will be no exceptions granted to this new requirement that would allow employers to submit this data on paper.
- OSHA is estimating that it will take employers about 10-minutes to create an account, another 10-minutes to log information from the 300A form, and then an additional 12-minutes PER INCIDENT listed on the OSHA 300 Form (which will only apply to companies with 250 or more employees).
- The information submitted will be published on OSHA’s website and accessible to the public. Employee names and other personal/sensitive information will be withheld.
- Additional language has been added to the Recordkeeping Rule in order to emphasize the importance of employers structuring their injury reporting/management practices to avoid retaliation. This may result in OSHA taking an even harder look at how disciplinary action, incentive programs, and post-accident testing is structured.
- While state plans are typically allowed to delay new rules/revisions for 60-days, this revision allows state plans to delay it for 6-months.
For more information on this new change, please click here.
