Recordkeeping, Special Topics in Safety Management

Recordkeeping Reminder: Get Your 300As to OSHA by July 1!

The deadline for affected employers to electronically submit calendar year 2017 injury and illness data to OSHA is just days away. By July 1, 2018, all employers covered by OSHA’s electronic recordkeeping requirements are required to submit data from their calendar year 2017 300A form (Annual Summary of Work-Related Injuries and Illnesses).
Records
The submission requirement applies to all establishments with 250 or more employees that are required to keep injury and illness records, as well as establishments with 20-249 employees in designated high-hazard industries.

OSHA’s high-hazard industry list includes over 60 North American Industry Classification System (NAICS) codes, some at the 2-digit major industry sector level, and others at the more detailed 4-digit industry group level. All establishments with 20-249 workers in agriculture, forestry, fishing, and hunting; utilities; construction; manufacturing; and wholesale trade are required to submit data by the July 1 deadline. Other affected industries include various subsets of retail trade, transportation, warehousing and storage, waste management, health care, accommodations, food service, and other services. The full list is available at https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.html.

Employers that are required to submit data electronically must do so using OSHA’s Injury Tracking Application (ITA), available at https://www.osha.gov/injuryreporting/ita/. There are three options for submission. Employers can:

  1. Enter data manually;
  2. Upload a CSV file to process single or multiple establishments at the same time, or
  3. Transmit data electronically via an application programming interface (API), for users of automated recordkeeping systems.

State-Plan States

States with federally approved occupational safety and health regulatory plans (state-plan states) are required to adopt rules that are at least as effective as those of federal OSHA. However, some states have not yet completed their adoption of the electronic recordkeeping rule.

In April, OSHA announced that affected employers in state-plan states that have yet to adopt the electronic recordkeeping rule are nevertheless required to submit their 300A data by the July 1 deadline. (These states include California, Maryland, Utah, Washington, and Wyoming.) Employers in those states are required to use federal OSHA’s Injury Tracking Application (ITA) to submit their data.

Some states, such as Washington and Wyoming, have disputed federal OSHA’s authority to require establishments under state plan jurisdiction to follow the federal requirements, and OSHA has admitted that it does not have the authority to cite employers in those states that fail to submit their 300A data by the July 1 deadline. Nevertheless, employers in state-plan states are advised to submit 300A data to federal OSHA by the July 1 deadline.

Public-sector employers in Illinois that are covered by the electronic recordkeeping rule have until September 30, 2018, to submit their data. South Carolina is granting employers an extra 6 months to submit data, resulting in a deadline of November 25, 2018; however, the state encourages employers to meet the July 1 deadline if possible.