Enforcement of OSHA’s electronic reporting requirements in its recently revised recordkeeping rule starts in most states on December 15, 2017. However, some of the OSHA state-plan-states have not yet adopted the requirement to submit recordable workplace injury/illness data electronically. The following OSHA-approved State Plans have not adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY. Establishments in these states are not currently required to submit their summary data through the Injury Tracking Application (ITA). Contact information for each of the State Plans can be found at https://www.osha.gov/dcsp/osp/states.html.

For states that are affected by the revised rule, enforcement dates are as follows.

Enforcement Dates:

Employers of 250 or More Employees (large employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 2017.  Going forward, large employers will be required to electronically submit to OSHA information from their OSHA 300 Log, OSHA 300 A Summary, and OSHA 301 Incident Report Forms once each year. The 2017 information must be submitted by July 1, 2018. However, starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2nd.

Employers of 20 to 249 Employees (small employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 2017.  The 2017 information must be submitted by July 1, 2018. Starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2nd.

Electronic Submittal Information and Portal – Improve Tracking of Workplace Injuries/Illnesses

MCAA Safety Bulletin – Improve Tracking of Workplace Injuries/Illnesses

OSHA Final Rule – Improve Tracking of Workplace Injuries/Illnesses

Entering into a joint venture with another company on a project can bring many benefits—sharing of costs, spreading the risk, pooling equipment, increasing labor, among other advantages. Like most other business arrangements, however, there are issues that may complicate a joint venture. Two Management Methods Bulletins bring these to light.

Basic information that you should know when you consider a joint venture arrangement is laid out in Joint Ventures. Along with the many pluses that come with a joint venture are some suggestions about how to approach the arrangement, when and how to organize and finalize the agreement and the protections that are necessary to ensure a productive and profitable relationship.

Becoming involved in a business arrangement with another company that’s not in the state where your company is incorporated can be complicated. State laws consider out-of-state companies to be “foreign corporations” and therefore must meet certain qualifications to legally transact business. Failure to do so will bring severe penalties to your company as well as the other company in your joint venture. Failure of One Corporate Member of a Joint Venture to Qualify as a Foreign Corporation May Penalize All Venturers alerts you to the issues that you may face when you embark on an out-of-state joint venture.

Joint ventures can be very beneficial business arrangements for all parties involved, but make sure you are fully aware of all the issues involved in such agreements before making a commitment.

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Enforcement of the electronic reporting requirements in OSHA’s recently revised recordkeeping rule has been delayed to December 15, 2017.

Enforcement Dates:

Employers of 250 or More Employees (large employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 2017.  Going forward, large employers will be required to electronically submit to OSHA information from their OSHA 300 Log, OSHA 300 A Summary, and OSHA 301 Incident Report Forms once each year. The 2017 information must be submitted by July 1, 2018. However, starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2nd.

Employers of 20 to 249 Employees (small employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 2017.  The 2017 information must be submitted by July 1, 2018. Starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2nd.

Electronic Submittal Information and Portal – Improve Tracking of Workplace Injuries/Illnesses

MCAA Safety Bulletin – Improve Tracking of Workplace Injuries/Illnesses

OSHA Final Rule – Improve Tracking of Workplace Injuries/Illnesses