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The federal Occupational Safety and Health Administration (OSHA) has released a proposed rule seeking to defer the date by which certain employers are required to electronically submit the information from their completed 2016 Forms 300A. The proposed rule would move the initial submission date from July 1, 2017, to December 1, 2017.

OSHA also expects to launch its electronic data collection system by August 1, 2017.

Background

In 2016, OSHA published a final rule, generally effective as of January 1, 2017, which requires certain employers to electronically submit injury and illness data to the agency as follows:

 

  • Establishments with 250 or more employees in industries covered by the recordkeeping regulation were to submit information from their 2016 Forms 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with 20-249 employees in certain high-risk industries such as Construction, Manufacturing, Wholesale trade, etc. were to submit information from their 2016 Forms 300A by July 1, 2017, and their 2017 Forms 300A by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA (however, employers with more than 10 employees and whose establishments are not classified as a partially exempt industry must otherwise comply with applicable OSHA recordkeeping provisions).