Workplace safety is a key part of a company’s day-to-day operation. Recently the Occupational Safety and Health Administration (OSHA) enacted a new rule to ensure even greater accountability for employers with more than 20 employees. The new rule requires existing OSHA reporting to be completed electronically, and while the implementation date has been postponed, employers should be prepared to satisfy the new requirement.
What is OSHA 300A?
OSHA 300A, Summary of Work-Related Injuries and Illnesses, is a form that must be submitted annually by employers with more than ten employees to report on-the-job injuries or illnesses. The forms must be kept on site for five years and must also be posted February through April of each year.
What is the new rule about?
The new OSHA rule requires certain employers with 20 or more employees to file 300A electronically. Companies with 20-249 employees in certain industries must file the form electronically. A full list of those industries can be found on the Department of Labor website. Companies with 250 or more employees must file Forms 300, 300A, and 301 electronically.
The rule also states that data filed via OSHA 300A will be made publicly available on OSHA’s website to nudge employers to have a greater focus on workplace safety.
While the rule took effect Jan. 1, companies are not yet required to implement the standard, and OSHA is not currently accepting online form submissions, though expects to be able to do so by August 1.
OSHA initially announced a July 1, 2017, deadline for electronically submitting Form 300A for 2016 data but has since indicated that it would move that date back, potentially to December 1, 2017. Comments on the proposed date change are being accepted through July 13, 2017, via regulations.gov, mail or fax. Visit the Federal Register website for details. [Update: OSHA has exended the deadline once again, changing the due date from December 1, 2017, to December 15, 2017.]
How will my company file OSHA 300A?
You will file the form through the OSHA website using one of three options: a fillable web form, a CSV file that will allow you to file single or multiple establishments at the same time, or through an API (application programming interface) if your company uses an electronic recordkeeping system.
What’s the purpose of the new rule?
OSHA has given several reasons for the new requirement for electronically submitting workplace illness and injury data. The foremost reason is that the organization believes this will improve safety for workers across the country. The organization will post some of the data publicly, allowing employees, potential employees, and the rest of the general public to see how companies are performing.
Additionally, OSHA states that receiving the data electronically will allow it to better allocate enforcement and compliance assistance resources. The organization says it believes the change will also eventually help companies’ bottom lines as they see a decrease in workplace safety incidents.
What else should I know about OSHA 300A?
It’s important to note that a key part of OSHA’s requirement states that employers should notify their employees of their right to report work-related injuries and illnesses and provide a reasonable procedure for them to do so. The notification requirement can be satisfied through placement of the OSHA workplace poster that’s already required to be posted.
Since this rule was finalized, a new labor secretary has taken office and therefore changes certainly cannot be ruled out. Employers should proceed as if the rule will take effect but remain alert for updates from the Department of Labor.
OSHA recordkeeping requirements and updates
Note: This post was updated on July 21, 2017, with the date the OSHA electronic filing website is expected to be available (August 1), and on November 30, 2017, with the extended due date for submission.