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Final Rule Issued to Improve Tracking of Workplace Injuries (Updated 11/29/2017)

OSHA updated its recordkeeping rule requiring employers to electronically submit injury and illness data. The new rule, which took effect on January 1, 2017, requires certain employers to electronically submit injury and illness data, which they already are required to record on their onsite OSHA Injury and illness forms. Analysis of this data will enable OSHA to use its enforcement and compliance assistance resources more efficiently. This regulation will improve the accuracy of this data be ensuring that workers will not fear retaliation for reporting injuries or illnesses.

So how will electronic submission work? OSHA has provided a secure website that offers three options for data submission. First, users are able to manually enter data into a web form. Second, users are able to upload a CVS file to process single or multiple establishments at the same time. Third, users of automated recordkeeping systems will have the ability to transmit data electronically via an application-programming interface (API). The Injury Tracking Application (ITA) is accessible from the ITA launch page ( where you are able to provide OSHA with your 2016 OSHA Form 300A information.

The rule also prohibits employers from discouraging workers from reporting an injury or illness. The final rule requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation, which can be satisfied by posting the already-required OSHA workplace poster. It also clarifies the existing implicit requirement that an employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting; and incorporates the existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses.

OSHA extended the 2017 compliance date for establishments with 20-249 employees in certain high-risk industries to electronically submit injury and illness reports from July 1st to December 15, 2017. Data from the 2017 Form 300A must be submitted by July 1, 2018. The OSHA definition of high-risk industries for purposes of this rule is extremely broad and includes virtually all manufacturing operations.

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.

Baron Environmental Associates can assist with this electronic report submission. Contact any of our EHS professionals through email or by phone at 908-508-9000.

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