2017 Recordkeeping Update: What You Need to Know

With all the updates to OSHA’s recordkeeping standards in the past few years, making sure your company is compliant with the latest requirements is a crucial task. Looking at the latest rule, which took effect January 1, 2017, certain employers are now required to submit their injury and illness data electronically. Although this may be a seemingly small change, since it is just making electronic the data employers already fill out, this change will no doubt improve workforce safety in three crucial ways:

1. OSHA will be able to quickly analyze the data and be more efficient in its regional enforcement and compliance.
2. Injury information submitted electronically will be publicly available, putting focus on unsafe workplaces. This will help job-seekers, workers, and customers make informed decisions in relation to the company they choose to work with. For companies, this will make it critical that safe work practices are followed.
3. Requiring information in this manner will improve accuracy of the data, since the update comes with an anti-retaliation protection. Employers must inform employees of their rights when reporting any work-related injuries and illnesses free from retaliation. This protection, in effect since December 1, 2016, clarifies the reasonableness of employers’ workplace policies regarding reporting work related injuries and illnesses.

Starting February 2017, there will be three options for electronic submission of injuries. Once live, this will be displayed prominently on the OSHA homepage.

1. Employers will be able to enter the data manually in a secure web form.
2. Employers can upload a CSV file to process single or multiple establishments at once.
3. Employers who use automated recordkeeping systems can transmit data via an API (application programming interface).

According to OSHA, this change will apply to “establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.” Those establishments with 250 or more employees must use the electronic submission for OSHA Forms 300, 300A, and 301.* Covered establishments with an employee count from 20-249 must submit the 300A form electronically. Since January 1, 2017, the recordkeeping update is effective and will be phased in over a two-year period. All covered establishments must submit their 300A electronically by July 1, 2017. For state plans, requirements must be updated to be substantially identical to the federal requirements within 6 months from the date OSHA published the final rule. Beginning in 2019, after the two-year phase in, covered establishments will have until March 2 to submit their information. To stay up to date on OSHA compliance, check out our OSHA Outreach courses for both construction and general industry, as well as a slew of helpful safety courses. * This does not erase the requirement to maintain records at the worksite for at least 5 years and post the summary of injury and illnesses from the previous year each February through April.