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Cashins & Associates Blog

OSHA Proposed Rule: Electronic Recordkeeping Requirements

Posted by Eileen Watkins on Tue, Feb, 04, 2014 @ 15:02 PM

OSHAMost US businesses are very familiar with OSHA's requirements to keep a log of all workplace illnesses and injuries (OSHA Form 300) and to post a workplace illness and injury summary report each year (OSHA Form 300A).  While these forms must be kept for a period of 5 years following the year that they were completed, they are not sent to OSHA unless a company is specifically asked to do so.   

OSHA sees this lack of "direct, timely, and systematic access" to injury and illness data as a lost opportunity for many entities, including the government, researchers, employers, and even employees.  The data on these forms tell who is getting injured and ill on the job, highlight injury and illness trends, and point out injuries and illnesses that are common to certain industries.

The forms also tell a compelling story about workplace hazards, as those of us in the safety and industrial hygiene business know that every workplace injury and illness has a hazard as its root cause.  We appreciate that timely responses to hazardous conditions reduce the risk of additional injuries and illnesses occurring.  We also understand that timely responses reduce the chance of a hazardous condition becoming a bad habit that is then ingrained in a company's culture.   

These issues are the backdrop for OSHA's proposed rule to improve the tracking of workplace injuries and illnesses.  This rule, if adopted, would add 3 new electronic reporting elements to its current recordkeeping regulations:

  • Businesses with 250 or more employees and who are currently required to use OSHA Forms 300 and 300A would be required to electronically submit information from these forms each quarter
  • Businesses in designated industries who have 20 or more employees and are currently required to use OSHA Forms 300 and 300A would be required to electronically submit information from the 300A form annually
  •  All businesses who are notified by OSHA to electronically submit specific information from their workplace injury and illness records must do so

Electronic submissions would be made either to OSHA or an OSHA designee using a secure web site.  Employers would register their businesses on this web site, then be assigned a login ID and password.  Data can be entered directly or by uploading a batch file.  

Stakeholder meetings for this proposed rule were held in May and June of 2010.  The Notice of Proposed Rulemaking (NPR) was filed in November of 2013.  An informal public meeting was held in January 2014 and the public comment period has been extended to March 8, 2014.  More information can be found on OSHA's website (www.osha.gov).

These proposed amendments do not change any of the current requirements to document workplace injuries and illnesses using OSHA Forms 300 and 300A.  Rather they add an electronic reporting obligation to many employers.  Their adoption would help OSHA and others to identify and address current workplace hazards.  These actions would in turn promote safer workplaces.

Do you understand your current OSHA illness and injury reporting obligations?  Have you identified the hazards at your workplace that put your company at risk for illnesses and injuries?  Do you need help addressing these hazards?  Click on the link below for a free inquiry.

Free Safety and Health Inquiry


Topics: OSHA

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