OSHA’s New Final Rule Makes Recordkeeping Logs For Workplace Injuries And Illness Available To Public
With the exception of employers with less than 10 employees and those exempt due to their low hazard nature (retail, finance, service, real estate, insurance, etc), most employers are covered by OHSA’s recordkeeping rule for recording and reporting workplace injuries and illness. In the latest of OSHA workplace injury rules, a new final rule has been implemented that will require these companies to go one step further and electronically submit their logs containing injury and illness data to OSHA. This will allow for better data analysis by OSHA and its resources for compliance and enforcement, and most importantly, it will make the data available to the public, including workers, investors, prospective employees, customers, and analysts.
The hope is that through the public disclosure of workplace safety data for individual employers, those with high injury incidence and lagging safety processes will be naturally “encouraged” to make improvements.
What Is Required Under The New OSHA Workplace Injury Rules?
The new final rule revises the regulation for Recording and Reporting Occupational Injuries and Illnesses. Under the existing regulation, most employers are already required to maintain logs for injury and illness and report them under forms 300, 300A, or 301. The industry and size of an employer both factor into which forms an employer is required to use.
Under the new final rule, these forms must now be electronically submitted to OSHA on an annual basis per the following guidelines:
- Employers with 250+ employees must electronically submit forms 300, 300A, and 301.
- Employers with 20-249 employees in these industries are required to electronically submit form 300A only.
It is important to note that there are no changes to the current requirements for collecting and maintaining records under OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation; the recording criteria and definitions also do not change. The only change comes in the electronic submission to OSHA on an annual basis, which is scheduled to begin January 1, 2017. Covered employers will receive additional instructions for electronic submission later this year.
Phased in Compliance Schedule
| Submission Year | Establishments with 250 or more employees | Establishments with 20-249 employees | Submission deadline |
| 2017 | Form 300A | Form 300A | July 1, 2017 |
| 2018 | Forms 300A, 300 & 301 | Form 300A | July 1, 2018 |
| 2019 & on | Forms 300A, 300 & 301 | Form 300A | March 2nd |
How The Final Rule Ensures Accuracy Of Data
Even with current regulations that require employers to maintain illness and injury reports, there are some employers who quietly discourage workers from reporting injuries. The new final rule requires employers to inform employees about their right to report an injury without the fear of retaliation, clarifies the requirement that employers must have a reasonable process for reporting workplace injuries that does not deter or discourage employees, and reinforces the current statutory prohibition on employers retaliating against employees for reporting work-related injuries.
Ideally, this will lead to more complete and accurate data that can be used to improve workplace safety processes.
Optimum Safety Management Can Help Ensure Your Compliance
If you need clarification on the requirements for your business, Optimum Safety Management can explain your obligations and help you improve your recording and reporting processes. We can also help identify, implement and improve workplace safety procedures so that you can be an industry leader for minimal injuries and incidents.
Learn more by scheduling your initial consultation with Optimum Safety Management. Call 630-759-9908 or contact us online today.
