Cashins & Associates Blog

Health and Safety - OSHA Logs:  New Electronic Submittal Requirement

Posted by Eileen Watkins on Tue, Jun, 07, 2016 @ 11:06 AM

Health-and-safety.jpgDid you know that OSHA recently revised its "Recording and Reporting Occupational Injuries and Illnesses" rule?  While a few paragraphs in 29 CFR Part 1904 were amended, the requirement for companies to electronically submit information from their OSHA logs is stealing the headlines. This article will help you understand this new requirement and the other changes that were made to this rule.

It's important to note that the requirement to record occupational injuries and illnesses - and post the OSHA 300A form in the workplace between February 1st and April 30th of each year - applies to many businesses and has been in place for decades.  The revisions take the old requirements a step further by requiring that this information be shared with OSHA. 

In brief, the electronic submittal effects 2 different groups of employers:

  1. Those having 250 or more employees and who are already required to keep workplace injury and illness records
  2. Those having between 20 and 249 employees and who are in OSHA-defined high risk industries (industries having certain NAICS* codes - see the following:  https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf)

Group #1 must electronically submit certain information from the following forms:  OSHA 300A, OSHA 300, and OSHA 301.   Group #2 must electronically submit information from their OSHA 300A form.

In all cases, the injury and illness data will be published on OSHA's website once personally identifiable information is removed.  This means that unlike in the past, when you could only see injury and illness information for your industry sector, you will now be able to see the data for individual companies. 

OSHA believes that this new requirement will do the following:

  • Motivate employers to improve their safety and health programs - and thereby reduce the number of workplace injuries and illnesses at their sites
  • Highlight high-performing companies and give them a competitive advantage over their under-performing peers
  • Help OSHA to better focus its outreach and enforcement activities
  • Help occupational health researchers to more quickly identify new health and safety hazards and/or trends

The deadline to electronically submit the required injury and illness information for this calendar year is July 1, 2017.  Submittals are also due on July 1st in 2018, but after that the deadline will be shifted to March 2nd of each year.  OSHA will provide a secure website for these electronic submissions, although information regarding the submittal process is not currently available. 

Finally, other revisions to part 1904 include:

  • Establishing a procedure whereby employees report workplace injuries and illnesses
  • Informing employees of this procedure
  • Prohibiting employers from discriminating against employees who report workplace injuries and illnesses
  • Allowing OSHA to request injury and illness data from employers who don't normally submit this information to the Agency

You can learn more about this new rule by going to OSHA's website:  https://www.osha.gov/recordkeeping/finalrule/index.html

*North American Industry Classification System

Do you need help understanding this new rule?  Evaluating or improving your safety program?  Cashins & Associates consultants provide a wide array of health, safety, and environmental services.  Send us your inquiry today!

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