Back in May 2016, we wrote about OSHA’s Final Rule, which requires certain employers to electronically submit worker injury and illness data for public display. Although OSHA already requires employers to report serious injuries, this new rule will require certain employers to report a lot more injury and illness data via secure website. Specifically, many employers will now be required to electronically file Injury and Illness Recordkeeping Logs (Forms 300A, 300, and 301). The reporting frequency and content will vary depending on the size and industry of the employer, and more details can be found in our blog post from last year. OSHA plans to make the data available on its public website, meaning the information will be available to any interested parties, including customers, competitors, attorneys and union organizers.
OSHA recently announced it would delay the deadline to submit required injury data until December 15, 2017. This delay is not the first issued by OSHA. The submission deadline was originally set to July 1, 2017, however, on June 28, 2017, OSHA proposed to delay the deadline until December 1, 2017. Why has this deadline been a moving target? According to OSHA, the delays have been put in place to give employers more time to familiarize themselves with the reporting portal, called the Injury Tracking Application (or ITA).
With this new deadline fast approaching, employers now have more obligations to add to their end-of-year workload. If employers have not already done so, they should evaluate whether the rule applies to their facilities, set up an account for OSHA’s ITA portal and get familiar with the layout, and make sure they submit the proper injury data by December 15, 2017. Now is also a good time to review whether your organization is in compliance with all workplace safety obligations.