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OSHA Delays Electronic Recordkeeping Injury Reporting

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On January 1, 2017, OSHA officially put into effect a revision to workplace injury and illness reporting that requires certain employers to submit recorded information of these instances electronically.  Companies were to submit all of this information from the previous year (2016) by July 1, 2017, but now that due date is in jeopardy.

OSHA’s recordkeeping website has recently been updated to include this note: “OSHA is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically.”  No timeframe for when the electronic submissions will now be due has been released yet.

According to the new rule, companies with 250 or more employees were required to submit form 300A by July 1, 2017 with 2016 information.  For their 2017 information, those same companies would be required to submit forms 300A, 300, and 301 by July 1, 2018.

For companies that have 20-249 employees and that are in high risk industries like construction, only form 300A will need to be filled out with the previous year’s information on July 1st every year.

Form 300A is a high level overview of injury and illness numbers for the previous year. Form 300 is a more in-depth log of injuries and illnesses that include names of the employees and other information. Form 301 is an incident report that includes more detail about individual injury/illness events.  All 3 forms can be found by clicking here.

The National Association of Home Builders has been a strong opponent of the electronic record-keeping requirement.  Shortly after the rule was made effective, the organization filed a challenge against OSHA, citing concerns of reputational harm to employers and an overreach of governmental authority.

OSHA Injury and Illness Recordkeeping and Reporting Requirements | OSHA

On January 1, 2017, OSHA officially put into effect a revision to workplace injury and illness reporting that requires certain employers to submit recorded information of these instances electronically.  Companies were to submit all of this information from the previous year (2016) by July 1, 2017, but now that due date is in jeopardy.

The worst day on the job is when someone on site gets injured.  The 2nd through 500th worst days are the legal battle that follows many of those injuries.  Nobody expects accidents to happen, but it’s best to be adequately prepared if one does.  That not only includes knowing how to react to injuries with a safety plan, but also making sure your company’s documentation is in order in case lawsuits start flying.

There’s no doubt that construction workers love a good prank and some of them get pretty creative.  Our favorites in the past have included the seismic test prank, the fake bear on site prank, and the “staple in the finger” prank.  Obviously, as far as messing around on the job site goes, the least dangerous as the prank is, the better. 

Tracking employees instantaneously is a dream scenario for employers.  It gives them tons of data to analyze to determine where money can be saved and where resources can be placed to be most efficient.  The struggle is convincing the employees that tracking their every move is not going to get them in trouble or fired. There’s a balance in there somewhere and that’s the challenge facing both employers and tech companies right now.

Two of the most critical concepts of construction safety are the ability to see what you’re doing and to also be seen by others around you.  Construction workers rely heavily on their employer providing lighting systems when working in low light conditions, but those systems are not always adequate. 

Construction industry groups are applauding President Donald Trump’s decision to sign a measure that eliminates a rule that would allow OSHA to issue citations for recordkeeping violations up to 5 years old.  The previous statute of limitations was 6 months. 

Prior to January 20th, 2017, it was almost a daily occurrence for the Occupational Safety and Health Administration (OSHA) to issue a press release about a large fine they have recently levied against businesses.  Since January 20th, news coming directly from OSHA has been extremely sparse.  There were some updates, like the delay of their new silica dust exposure rule and information about their “Safe and Sound Campaign,”  but nothing about recent fines and citations.