OSHA has issued a final rule that will require all establishments with 250 or more employees in industries covered by the current recordkeeping regulation to electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A, and 301. Establishments with 20-249 employees in certain industries must electronically submit information from OSHA Form 300A only. This includes the LBM sector. These are new annual reporting requirements, with phased-in deadlines highlighted below.
State Plan states have six months to adopt requirements that are substantially identical to the requirements in this final rule. The new annual electronic reporting requirements are effective January 1, 2017, with a phased-in schedule based on the size of the establishment. For the calendar year 2017, establishments with 250 or more employees and those with 20-249 employees must submit Form 300A by July 1, 2017. For calendar year 2018 and thereafter, establishments with 250 or more employees must submit Forms 300A, 300 and 301 by July 1, 2018. Establishments with 20-249 employees are only required to file Form 300A. Beginning with calendar year 2019, the reporting deadlines will be moved from July 1 to March 2. OSHA intends to post the data from these submissions on a publicly accessible Web site. OSHA does not intend to post any information on the Web site that could be used to identify individual employees. The new rule also addresses how employers must inform employees of their rights to report work-related injuries and illnesses. For more information, read the NLBMDA Regulatory Alert: OSHA issues final rule on injury and illness electronic reporting. OSHA has posted online Frequently Asked Questions as well as a Fact Sheet that provide more information. These and other materials are available on OSHA’s webpage on the final rule.
Find NLBMDA’s Regulatory Alert: OSHA Issues Final Rule on Injury and Illness Electronic Reporting here. Please direct your questions to Frank Moore, NLBMDA's Regulatory Counsel at Frank@dealer.org.