Final Rule Issued to Improve Tracking of Workplace Injuries and Illnesses

The Occupational and Health Administration (OSHA) issued its controversial final rule to expand electronic recordkeeping requirements for the workplace on May 11, 2016.

The new rule provisions on reporting, which take effect on January 1, 2017, require various employers to submit injury and illness data electronically.  OSHA is requiring each and every establishment (i.e., each separate workplace) with 250 or more employees in industries covered by the recordkeeping regulation to submit information from their 2016 injury and illness recordkeeping Form 300A by July 1, 2017. The following year, these employers are required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018.  Beginning in 2019 and for every year thereafter, the information must be submitted by March 2.  For those employers who utilize an alternative to the OSHA Form 301, such as a workers’ compensation first report of injury, as expressly allowed by the existing rules, these changes will in essence require that the employer also complete the OSHA Form 301.  


Establishments with 20-249 employees in specified “high-risk industries” – identified on a specific list and including all employers in the agriculture, utilities, construction, and manufacturing industries – must submit their Form 300A by July 1 in 2017 and 2018, and by March 2 every year thereafter.  Because the information is kept and must be submitted by each establishment, many companies will be required to submit thousands of reports every year.  

Those employers with establishments that are not required to submit records yearly may still be required to submit information upon OSHA’s direction.  OSHA intends to provide notification of these data collections through direct mailings, publication in the Federal Register, and publication on its website and other notices. 

The rule also changes employer obligations for ensuring employees report all work-related injuries and illnesses.  Effective 90 days after publication of the rule, on August 10, 2016, employers must establish “a reasonable procedure” for employees to report work-related injuries and illnesses promptly and accurately.  

In order to prepare for the new rule, employers should:

  • Review and revise procedure for employees to report work-related injuries and illnesses promptly and accurately;
  • Ensure procedures include OSHA’s notice of the right to report and the assurance against retaliation;
  • Review and revise how the procedure is communicated to employees and update that communication for any revised procedure; and
  • Review all safety incentive programs to ensure they will not be alleged to deter or discourage a reasonable employee from accurately reporting a workplace injury or illness.

As with anything OSHA, compliance is important. If you need assistance in developing a electronic workplace injury and illness recordkeeping program, Capital Safety Services can assist you, just call 518.427.8405.


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