Cal/OSHA recently adopted emergency regulations requiring certain employers in California to electronically submit their 2017 Form 300A summaries of work-related injuries and illnesses to federal OSHA by December 31, 2018.
The following employers must electronically submit their Form 300A summaries covering the calendar year 2017 by the December 31 deadline:
• All employers with 250 or more employees, unless specifically exempted by section 14300.2 of Title 8 of the California Code of Regulations.
• Employers with 20 to 249 employees in the specific industries listed in Appendix H of the emergency regulations. (Ex: agriculture, construction, auto and furniture stores, department and grocery stores, trucking, and more.)
If you are on OSHA’s list follow the instructions on federal OSHA’s Injury Tracking Application webpage to submit your Form 300A summaries online.
In 2019, establishments that are required to submit under paragraph (a)(1) or (2) of this section will have to submit all of the required information by March 2 of the year after the calendar year covered by the form or forms (for example, by March 2, 2019, for the forms covering 2018).
This electronic reporting rule has had a long back-and-forth. Federal OSHA first passed the rule in 2016, but gave states like California, who have their own occupational health and safety plan, additional time to comply and to adopt their own recordkeeping rule. Last June, Fed OSHA stated that employers should comply with the electronic reporting requirement by July 1, 2018—even though California had not yet adopted its rule. Without a doubt, this led to confusion—hence the need for regulations to clarify the requirements here in California.