Regulatory Developments

Deadline Extended for Electronic Recordkeeping Compliance

The compliance deadline for the Occupational Safety and Health Administration’s (OSHA) electronic reporting of workplace injuries and illnesses has been extended 2 weeks to December 15, 2017. That’s still just around the corner.

electronic reporting recordkeeping filing

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OSHA extended the original deadline from July 1, 2017, to December 1, to give the Agency time to review the Improved Tracking of Workplace Injuries and Illnesses final rule and determine if the rule needs to be revised or if any provision should be removed. The new compliance deadline is December 15, 2017. But don’t think that this extension and Agency review of the final rule means you do not have to submit your completed 2016 300A forms electronically to OSHA. If you are required to do so you must!

Under the rule, private sector establishments that have 250 or more employees and establishments with more than 20 but fewer than 250 employees in high-risk industries listed in appendix A of the rule are required to submit their completed 2016 300A data via the Injury Tracking Application (ITA) – Electronic Submission of Injury and Illness Records to OSHA by December 15, 2017.
The data submission process involves four steps:

  1. Create an establishment;
  2. Add 300A summary data;
  3. Submit data to OSHA; and
  4. Review the confirmation e-mail from the Agency.

The secure website offers you three options for submitting your data. One option allows you to manually enter data into an online form. Another option gives you the ability to upload a CSV file (like an excel spreadsheet) to process a single or multiple establishments at the same time. For the third option, if you use an automated recordkeeping system, you can submit your data electronically using an application programming interface—or API.

But let’s not forget public sector establishments. All public sector employers (establishments with 1 or more employees) must also use OSHA’s secure website to submit their 300A data.

The ITA website includes a lot of information to help you through the submission process.

Although there is uncertainty about the future of the rule, if you are an affected establishment that is required to submit records, familiarize yourself with the ITA site and submit your 300A data by December 15, 2017.