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OSHA Electronic Reporting Deadline is Fast Approaching

The electronic reporting deadline for establishments with 250 or more employees that are subject to OSHA's recordkeeping regulation is December 1.

By December 1, qualifying establishments must electronically submit to OSHA some of the information from the Log of Work-Related Injuries and Illnesses (OSHA Form 300), the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and the Injury and Illness Incident Report (OSHA Form 301).

Establishments with 20-249 employees in certain high-risk industries must electronically submit to OSHA some of the information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A). For ISRI members it is important to know that any industry that has a NAICS code starting with the first two numbers 42 falls in the category of high risk industry (423030 is the NAICS used by many scrap recyclers).

Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA.

The electronic reporting requirements are based on the size of the establishment, not the firm. The OSHA injury and illness records are maintained at the establishment or facility level. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment's peak employment level during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.

Establishments must submit their information electronically and may not submit the information on paper. Employers who do not have the necessary equipment or internet connection may submit their data from a public facility, such as a library.

OSHA has a secure website that offers the following three options for data submission:

  • First, users are able to manually enter data into a web form.
  • Second, users are able to upload a CSV file to process single or multiple establishments at the same time.
  • Lastly, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface). The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you are able to provide the Agency your 2016 OSHA Form 300A information.

For questions or more information, please contact Terry Cirone.

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