OSHA`s Final Rule on Electronic Filing of Injury and Illness Data
On May 12th, OSHA published its final rule “Improve Tracking of Workplace Injuries and Illnesses”, which includes changes related to electronic filing of information required to be maintained in 29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses regulation.
There are 3 main provisions of the new rule:
- First, it requires employers with more than 250 employees who are covered by the standard to report electronically the information contained on their 300, 300A, and 301 logs.
- Second, for employers with 20 to 249 employees that are in industries designated within the rule, they are required to electronically submit information from their 300A.
- Third, if other employers are notified, they too must report electronically for the period in which they were requested through the notification.
One final note about the new rule is that there is clarifying language which emphasizes the employer’s responsibility to inform employees of their right to report injuries and to ensure that the process or related programs do not discourage reporting by employees.
The rule takes effect in 2017 with delayed reporting dates. In 2017, employers have until July 1st to report and only need to report from their 300A. In 2018, they also have until July 1st, but employers with 250 employees or more will also be required to report 300 and 301 information. In 2019 and after, employers will need to report by March 2nd.
This new rule does not change any of the other elements outlined in 29 CFR 1904; criteria for reporting, posting of information, completion of the logs, etc. all remain unchanged. The primary change is the addition of electronic reporting.