RBS News

Written By: Brian K. Brittain | 2017-12-11

New OSHA Electronic Filing Requirements

The new OSHA electronic reporting requirement deadline is right around the corner!  Back in 2016, OSHA made many rule changes to their reasonable reporting and retaliation regulations.  More importantly, along with the other rule changes, OSHA issued a new rule mandating electronic filing of OSHA logs.  You can read more about the rule by following this link -- Electronic Reporting.  The rule was originally supposed to go into effect on 7/1/2017 but it encountered some delays due to pushback received on the rule.  However, the final deadline date, December 15, 2017, is now upon us.   

What does this mean for employers?

There are two categories of establishments that need comply with this new electronic reporting rule.  The first category is any company with 250 or more employees.  The second category is any company with 20-249 employees, classified within a certain industry.  (Click HERE for the industries impacted by this new rule.)  Further, this new rule will be phased in over a two year period.  On or before 12/15/17, any company with 250 or more employees, as well as companies in the 20-249 employee category in the stated industry classifications, are required to submit only the 2016 300A OSHA summary.

In 2018 the rule will expand requiring companies with 250 or more employees to electronically submit the 2017 OSHA 300, 300A and 301.  (Establishments with 20-249 will still only need to upload the 300A).  The filing deadline for 2018 will also change -- the new date is July 1, 2018.  In 2019 and thereafter, the submission deadline will once again change to March 2 of each year.  CRM will continue to keep you informed on any changes regarding this rule and will send reminders as other deadlines approach.  

How is electronic reporting done?

On or before December 15, 2017, you will need to set up an account, create an "establishment" and then upload the data.  You can do this here at the Injury Tracking Application (ITA) site.  Once you link to the site, you set up an account by clicking "create an account" (or you can click create an account to take you directly to the necessary screen).

We are committed to providing the best possible service to your company. If you have any further questions regarding this new regulation, do not hesitate to contact me at bbrittain@rbslaw.com or 216-447-1551

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