The Federal Register published a rule by the Occupational Safety and Health Administration (OSHA) Friday announcing an extension of the deadline for submission of Form 300A.
This is yet another extension of the due date for electronic filing of Form 300A for 2016 data. The original due date was July 1, 2017. A proposal to change the deadline to December 1, 2017, was presented by OSHA in June and comments on the proposed date change were accepted through mid-July.
One of the reasons for the delays is the electronic reporting system for submitting 300A was not accessible by employers for most of the year, having come online August 1. Additionally, the electronic reporting system was taken off-line for several days in August as a precautionary measure to scan the system after an alert from Homeland Security indicated a possible compromise of data. Ultimately no issue was found, and the system was back online later that month.
This is the first year many employers are required to submit the form electronically, though the form and rules around maintaining and posting related data have not changed. The change in reporting method is outlined in detail in the original Improve Tracking of Workplace Injuries and Illnesses rule, published May 12, 2016. The rule also states that data reported on Form 300A will be posted on a public website; personally-identifiable data will not be included.
More information and helpful links are available at our blog post, OSHA 300A Electronic Filing Requirement.