OSHA’s Electronic Reporting Deadline is Dec. 15, 2017
On Nov. 24, 2017, OSHA issued a new final rule officially delaying the first electronic reporting deadline to Dec. 15, 2017. Affected establishments will need to submit their reports through the Injury Tracking Application (ITA) website by that time or face possible OSHA penalties.
OSHA’s final rule on electronic reporting requires certain employers to submit data from their injury and illness records electronically so it can be posted on the agency’s website. Because the rule is an extra requirement on top of existing OSHA recordkeeping standards, affected employers need to be ready to comply with the rule before the Dec. 15, 2017, deadline.
The rule doesn’t change an employer’s requirements to complete and retain regular injury and illness records, but some employers will now have additional obligations. OSHA’s electronic reporting rule affects:
- Establishments with 250 or more employees that are required to keep injury and illness records.
- Establishments with 20 to 249 employees and belong to a high-risk industry.
- Establishments that receive a specific request from OSHA to create, maintain and submit electronic records, even if they would otherwise be exempt from OSHA recordkeeping requirements.
The electronic reporting rule applies to establishments, not employers. An employer may have several worksites or establishments. In these situations, some establishments may be affected while others are not.
To determine whether an establishment is affected, employers must determine each establishment’s peak employment during the calendar year. During this determination, employers must count every individual that worked at that establishment, regardless of whether he or she worked full-time, part-time, or was a temporary or seasonal worker.
Finally, a firm with more than one establishment may submit establishment-specific data for multiple establishments.
The final reporting requirements will be phased in over two years. After the initial Dec. 15, 2017 deadline, establishments with 250 or more employees must submit information from OSHA Forms 300, 300A and 301 by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
Submitting the Report
The ITA is a secure website that OSHA created specifically for the data required by the electronic reporting rule. The ITA allows employers three options to submit their reports:
- Manual entry;
- Comma-separated value (CSV) file upload; and
- Application programming interface (API) transmission.
Need assistance to prepare for this new rule? Call us at (616) 942 – 5070 and ask to see our comprehensive Compliance Overview on OSHA’s electronic reporting rule.
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