Regulatory Updates: "OSHA LOG" update!

Effective January 01, 2017, OSHA’s new rule Improve Tracking of Workplace Injuries and Illness has been finalized to amend the current Recording and Reporting Occupation Injuries and Illness regulation.  The following points are notable highlights:

1.      Certain employers will be required to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms under existing regulations.

2.      Data will be publicly available for examination by researchers to detect trends and identify workplace safety hazards before they become widespread.

3.      Employers are encouraged to increase injury and illness prevention efforts and workers are encouraged to report work related injuries and illnesses without the fear of employer retaliation.

4.      OSHA’s existing recordkeeping regulation will clarify the rights of employees and their representatives to access public injury and illness records under the amendments of specified in the new rule.

OSHA has provided a secure website that offers three options for data submission. First, users will be able to manually enter data into a web form.  Second, users will be able to upload a CSV file to submit mass information.  Last, users will have the ability to transmit data electronically via an API (application programming interface).  Electronic submission requirements do not change an employer’s obligation to complete and retain injury and illness records.

The following table illustrates the phases of reporting requirements for OSHA forms 300 – Log of Work-Related Injuries and Illnesses, 300A – Summary of Work-Related Injuries and Illnesses, and 301 – Injury and Illness Incident Report:

Submission year	20-249 employees	250 or more employees	Submission deadline
2017	Form 300A	Form 300A	July 1, 2017
2018	Form 300A	Forms 300A, 300, 301	July 1, 2018

More information can be found on the OSHA website. Here is a quick link to the OSHA fact https://www.osha.gov/Publications/OSHA3862.pdf

Here is a link to the final rule published in the federal register: https://www.federalregister.gov/documents/2016/05/12/2016-10443/improve-tracking-of-workplace-injuries-and-illnesses