New OSHA Rule – Electronic Record-keeping

The U.S. Occupational Safety & Health Administration (OSHA) has issued a final rule that (among other things) requires certain employers to electronically osha_logosubmit injury and illness data.

Final Rule
The new rule, generally effective January 1, 2017, requires certain employers to electronically submit injury and illness data to OSHA that they are already required to record on their OSHA injury and illness forms, as follows:

  • Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Forms 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Forms 300A by July 1, 2017, and their 2017 Forms 300A by July 1, 2018. Beginning in 2019, the information must be submitted by March 2.
  • Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA (however, employers with more than 10 employees and whose establishments are not classified as a partially exempt industry must otherwise comply with applicable OSHA recordkeeping provisions).
    Note: OSHA “State Plan” states must adopt requirements that are substantially identical to the requirements in the final rule within 6 months after the rule’s publication (listed as May 12, 2016).

Further details and requirements are contained in the final rule. Additional resources, such as a fact sheet and FAQs, are available by clicking here.

For OSHA forms, click here.