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Get Me Off this Merry-Go-Round! OSHA (Again) Revises Electronic Injury and Illness Recordkeeping Rules; Posting Deadline Remains

Tags: OSHA
Posted by: Gail Cecchettini Whaley, Esq. on Thursday, January 31, 2019 at 8:00:00 am

The federal Occupational Safety and Health Administration (OSHA) recently published a Final Rule to amend its workplace injury and illness recordkeeping regulation. The amendment rescinds the requirement for establishments with 250 or more employees to electronically submit the Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report).

However, covered establishments are still required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Likewise, last year Cal/OSHA adopted emergency regulations requiring these covered establishments to electronically submit Form 300A.

Remember, not all establishments are covered by this requirement. Review which establishments need to provide their data here.

Covered establishments must electronically submit their completed 2018 Form 300A information by March 2, 2019.

If you are a covered establishment follow the instructions on federal OSHA’s to submit your Form 300A summaries online.

EIN requirement

OSHA also added a new requirement—covered establishments must submit their Employer Identification Number (EIN) electronically along with their Form 300A submission. The compliance date for employers providing their EIN is March 2, 2020. In other words, no EIN is required for the 2018 Form 300A submissions (due to be electronically filed no later than March 2, 2019); an EIN is required for each establishment electronically filing the 2019 Form 300A (due by March 2, 2020).

OSHA stressed that nothing in the final rule revokes an employer’s duty to maintain OSHA Forms 300 and 301 for OSHA inspection. All of these new actions together will permit OSHA to "improve enforcement targeting and compliance assistance, decrease the burden on employers, and protect worker privacy and safety."

Form 300A Posting Requirement Begins February 1

Separate from the electronic submission requirement, employers still are required to post the Form 300A summary of work-related injuries and illnesses. The summaries must be posted from February 1 through April 30 and must be placed in a visible and accessible area at each worksite.

The definitions and requirements for recordable work-related fatalities, injuries and illnesses are outlined in the California Code of Regulations, Title 8, sections 14300 through 14300.48.

Instructions and form templates can be downloaded free from Cal/OSHA’s Recordkeeping Overview. The overview gives instructions on filling out both the log (Form 300) and annual summary (Form 300A) of Work-Related Injuries and Illnesses. The annual summary must be placed in a visible and easily accessible area at each worksite. Current and former employees, as well as employee representatives, must be allowed to review the summary in its entirety.

Employers are required to complete and post Form 300A even if no workplace injuries occurred. More information on posting requirements or how to reduce workplace injuries and illnesses is available on the DIR’s Employer Information webpage.

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