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Electronic Reporting of Workplace Injuries and Illnesses Delayed Until December?

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The federal Occupational Safety and Health Administration (OSHA) has proposed a delay to the July 1, 2017, reporting deadline for electronic reporting of injury and illness data. The  Final Rule, published May 12, 2016, and effective January 1, 2017, now has a proposed deadline of December 1, 2017, for initial reporting. The delay is intended to allow the new administration an opportunity to review the Final Rule’s requirements before implementation and allow affected employers enough time to familiarize themselves with the new electronic reporting system, which is now expected to be available by August 1, 2017.

Under the Final Rule, employers with establishments having 250 or more employees that are required to keep 29 CFR part 1904 records are required to electronically submit certain information from their completed 2016 300A Logs to OSHA through a secure website. These same employers would then be required to submit that information from all of their 2017 forms (the 300A, 300, and 301 forms) by July 1, 2018. March 2 nd would then be the annual deadline for electronic reporting beginning in 2019 and thereafter.

In addition, employers with 20 — 249 employees in  certain high-risk industries must electronically submit certain information from their 2016 300A Logs by the new deadline and their 2017 300A Logs by July 1, 2018; beginning in 2019 and thereafter, these employers must electronically submit the information annually by March 2 nd.

The Final Rule also required employers to inform their employees of their right to report work-related illnesses and injuries free from retaliation, ensured the procedure for reporting does not discourage employees from reporting illness or injury, and clarified the right of both employees and their representatives to access injury and illness records.

OSHA State Plan states must adopt requirements that are substantially identical to the new requirements in the Final Rule within six months of publication.

Although the information that would be required to be electronically submitted is already required to be maintained, the new rule allows OSHA to post data from these submissions on a publicly accessible website. No information that could be used to identify individual employees would be posted. OSHA intends to use the information to utilize its enforcement and compliance assistance resources more efficiently. OSHA also believes that public disclosure  “will encourage employers to improve workplace safety and provide valuable data to workers, job seekers, customers, researchers and the general public.”

Public comments on the proposal to delay the electronic reporting deadline are being accepted until July 13, 2017. See the  proposed rule for more information.

If you have questions about the new “Improve Tracking of Workplace Injuries and Illness” rule, then please contact our content team at

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