Effective 1/1/17, a new OSHA rule requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite Injury and Illness forms (300, 300A, and 301). OSHA believes this will enable them to use its enforcement and compliance resources more efficiently. Some data will also be posted on their website. They think this disclosure will encourage employers to improve workplace safety, and provide valuable information to workers, job seekers, customers, and the general public. What will be posted depends on the size of the company.

Our Sullivan Group HR clients will fall under the category of employers with 20 to 249 employees in certain high risk industries. They will only have to submit form 300A. Their 2016 form 300A will be due to be posted with OSHA by 7/1/17. The 2017 300A by 7/1/18, and beginning in 2019, and very year thereafter, it is submitted by March 2.

On our website,  you will find a list of the industries with 29 to 249 employees that must submit the Form 300A electronically. There also will be a copy of the forms 300, 300A, and 301 with instructions on how to complete. Reference the 300A that requires the number of hours worked during the reported year, we will provide that information to all clients as requested. Reference the completion of the OSHA forms, our Risk Manager, Richard Smith, will be available to Sullivan HR clients to answer questions to assist in Form completion.

For this current year 2016, be sure you are tracking the accident and injury data as they occur during the year to enable you to complete the OSHA 300 and 300A. The instructions for the Forms mentioned above on our website, will guide you as to what needs to be tracked post accident. For example, the type of recordable injuries such as those with lost days from work, or return to work, but with  restrictions, you need to keep track of the number of days for each type of injury.

As we get closer to the initial reporting date of 7/1/17, we will alert all our clients as to how the 300A is electronically submitted to OSHA.