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OSHA Electronic Submission Requirements Delayed Two Weeks

Last week OSHA announced that it has delayed the electronic submission requirements for employers covered by the recordkeeping requirements in Section 1904 until December 15, 2017.

As a reminder, establishments with 250 or more employees must submit information electronically from their 2016 Form 300A by December 15, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) beginning in 2018. Establishments with 20-249 employees operating in what OSHA deems to be “high-risk industries” (including those in the scrap recycling industry with NAICS code 423930) must submit information from their 2016 Form 300A by the December 15, 2017 deadline. These same employers will continue to only submit information from their 300A forms in later years.

The submission deadline was originally July 1, 2017, however, OSHA proposed to delay the date until December 1, 2017 to give employers additional time to become familiar with the portal, known as the Injury Tracking Application or ITA.

Unless an employer is under federal jurisdiction, the following OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically: California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming. Establishments in these states are not currently required to submit their summary data through the ITA. Similarly, state and local government establishments in Illinois, Maine, New Jersey, and New York are not currently required to submit their data through the ITA.

It is anticipated that OSHA will proposal additional changes to this rule in the near future and OSHA will issue another Notice of Proposed Rulemaking in the Federal Register next year.

For more information contact Terry Cirone

Leadership Update Main

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