Update on Enforcement of OSHA’s Electronic Reporting of Workplace Injuries/Illnesses Rule

November 14, 2017

Back in June, OSHA  issued a proposed rule to delay enforcement of the  electronic reporting requirements established in its  revised recordkeeping rule – Improve Tracking of Workplace Injuries and Illnesses.  The rule proposed to delay the enforcement date from July 1, 2017 to December 1, 2017. However, the proposed rule has still not been finalized. MCAA is unaware of any OSHA enforcement activity on the rule, and is uncertain whether the agency will begin or increase enforcement on December 1, 2017. MCAA recommends that members get into compliance with the rule by December 1st.

Enforcement Dates:

Employers of 250 or More Employees (large employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by July 1, 2017. (OSHA was not capable of receiving electronic submissions until August 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 information from their OSHA 300 A Summary once each year. The 2016 information was supposed to have been submitted by July 1, 2017. (OSHA was not capable of receiving submissions until August 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 BulletinImprove Tracking of Workplace Injuries/Illnesses

OSHA Final Rule – Improve Tracking of Workplace Injuries/Illnesses

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