Newsletters and Alerts: Employment Alert

​OSHA Finalizes Electronic Recordkeeping Submissions Deadline

Monday, December 4, 2017   (0 Comments)
Posted by: Emerald Stander
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Employment Law Alert: December 4, 2017
OSHA Finalizes Electronic Recordkeeping Submissions Deadline


UPDATE: On December 18, OSHA extended the filing deadline for the OSHA 300A to December 31st, 2017.

Certain Employers Must Electronically Submit 2016 Form 300A Data
OSHA’s final rule to Improve Tracking of Workplace Injuries and Illnesses sets December 15, 2017, as the date by which certain employers are required to electronically submit data from their 2016 Forms 300A to OSHA (a two-week extension from the December 1, 2017, compliance date in the proposed rule).

Who Must Comply?
By December 15, 2017, the following establishments—if currently required to comply with OSHA's recordkeeping requirements—are required to electronically submit data from their 2016 Forms 300A to OSHA:

  • Establishments with 250 or more employees; and
  • Establishments in certain designated industries with 20-249 employees.
Click here to see a list of designated industries. Oregon OSHA has announced it is adopting the revised Federal OSHA deadline of December 15th. Some “State Plan” states have not adopted the new requirements and, according to OSHA, establishments in California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming are not yet required to submit data.

Where Do I Submit the Data?
Covered establishments must submit the required data through OSHA’s online Injury Tracking Application

Who is currently required by OSHA to keep records?
Companies with more than 10 employees at any time during the last calendar year must keep complete OSHA Forms 300, 301, and 300A annually, unless they are classified as a partially exempt industry. Notable partially exempt industries include:
  • Retailers- including clothing, shoe, jewelry, sporting goods, and office supply
  • Physicians' and dentists' offices
  • Full-service restaurants
  • Child day care services
  • Religious organizations
OSHA is currently reviewing the other provisions of its final rule to Improve Tracking of Workplace Injuries and Illnesses, and intends to publish a notice of proposed rulemaking to reconsider, revise, or remove portions of that rule in 2018.

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