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Electronic Reporting Update

OSHA announced last week that it was temporarily shutting down a portal for employers to report injuries and illnesses while the agency investigates a “potential compromise” of a company’s electronic data.

The Homeland Security Department informed the Occupational Safety and Health Administration on Aug. 14 that “there is a potential compromise of user information for OSHA’s Injury Tracking Application,” according to the DOL official. . Access to the ITA has been temporarily suspended as OSHA works with the system developer to examine the issue to determine the extent of the problem.”

OSHA is currently working with the ITA developer to determine the extent of the problem and the potential impact to the portal. Users trying to access the portal will find an alert noting, “due to technical difficulties with the website, some pages are temporarily unavailable.” It is unclear whether this security breach will impact or further delay the compliance date for the submission of employer injury and illness information, which is December 1, 2017.

Regulatory Agenda

The DOL Regulatory Agenda Includes a total of thirteen regulatory entries for OSHA specific actions.  Additionally, sixteen agency actions have been removed completely from the current agenda, including Injury and Illness Prevention Program (IIPP) and Combustible Dust. These initiatives have been classified as “completed actions”, “OSHA is withdrawing this entry from the agenda at this time due to resource constraints and other priorities.

 For those initiatives remaining for OSHA, five of the thirteen rulemaking actions still are in the pre-rule stage.  At this stage, OSHA is simply gathering relevant information through stakeholder meetings or outreach measures.   The dates for regulatory activities in areas that impact ISRI members is provided below:

  • Powered Industrial Trucks - Request for Information in December 2017
  • Lock-Out/Tag-Out Update - Request for Information April 2018
  • Occupational Exposure to Beryllium - Notice of Proposed Rulemaking Comment Period Ends August 2018
  • Tracking of Workplace Injuries and Illnesses - Notice of Proposed Rulemaking in October 2017

The remaining eight regulatory actions are in the proposed rulemaking stage, and include rules that were promulgated and finalized under the Obama Administration and recently reopened under the Trump Administration, such as Occupational Exposure to Beryllium.

Much of the agency’s Walking-Working Surfaces and Personal Fall Protection Systems final rule, issued in November 2016 has gone into effect since January, and three of its six remaining provisions are scheduled to be phased in by the end of this year.

Along with the rulemaking on beryllium, proposed rules carried over from fall 2016 or added to the agenda that could impact ISRI operations include:

  • Quantitative Fit Testing Protocol: Amendment tothe Final Rule on Respiratory Protection
  • Technical Corrections to 16 OSHA Standards
  • Improve Tracking of Workplace Injuries and Illnesses

Lastly, the list of Long Term Actions that have an indefinite timeline for when they may see some regulatory activity include:

  • Update to the Hazard Communication Standard
  • Emergency Response and Preparedness
  • Occupational Injury and Illness Recording and Reporting Requirements – Musculoskeletal Disorders (MSD) Column
  • Rules of Agency Practice and Procedure Concerning OSHA Access to Employee Medical Record

 

OSHA launches application to electronically submit injury and illness data on August 1

On Aug. 1, 2017, OSHA will launch the Injury Tracking Application (ITA). The Web-based form allows employers to electronically submit required injury and illness data from their completed 2016 OSHA Form 300A. The application will be accessible from the ITA webpage.  OSHA also published a notice of proposed rulemaking to extend the date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically from July 1, 2017 to December 1, 2017.

The data submission process involves four steps: (1) Creating an establishment; (2) adding 300A summary data; (3) submitting data to OSHA; and (4) reviewing the confirmation email. The secure website offers three options for data submission. One option will enable users to manually enter data into a web form. Another option will give users the ability to upload a CSV file to process single or multiple establishments at the same time. A third option will allow users of automated recordkeeping systems to transmit data electronically via an application programming interface.

The ITA webpage also includes information on reporting requirements, a list of frequently asked questions and a link to request assistance with completing the form.

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