New Rule In Effect January 1!! OSHA is Changing the Way Some Employers Track Workplace Injuries and Illnesses.
December 2, 2016
OSHA has issued a new rule, involving injury and illness tracking, which goes into effect on January 1, 2017.
Employers in either one of the two categories described below, will be required to routinely submit injury and illness information, electronically, to OSHA as follows :
- Employers with 250 or more employees, covered by the record keeping regulation, must electronically submit information from their 2016 OSHA Form 300A- Summary of Work Related Injuries and Illnesses, directly to OSHA, by July 1, 2017. The electronic submission is in addition to their current method of recording the same data on their on-site OSHA Form. The same employers must electronically submit information from their 2017 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, in addition to their current method of recording, by July 1, 2018. Data for all required OSHA Forms, for each year thereafter, must be submitted by March 2, of the following year.
- Employers in certain high-risk industries, with 20-249 employees, must electronically submit information from their 2016 OSHA Form 300A-Summary of Work Related Injuries and Illnesses, directly to OSHA, by July 1, 2017. The electronic submission is in addition to their current method of recording the same data on their on-site OSHA Form. Those same employers must electronically submit data from their 2017 300A Form by July 1, 2018. 300A data, for each year thereafter, must be submitted by March 2, of the following year.
| Submission Year | Establishments with 250 or More Employees | Establishments with 20-249 Employees | Submission Deadline |
| 2017 (2016 Data) | Form 300A | Form 300A | July 1, 2017 |
| 2018 (2017 Data) | Forms 300, 301, 300A | Form 300A | July 1, 2018 |
| 2019 (2018 Data) | Forms 300 301, 300A | Form 300A | March 2, 2019 |
| Every Year Thereafter | Forms 300 301, 300A | Form 300A | March 2 |
OSHA will notify employers, not included in either of the two categories outlined above, in writing, if they are required to electronically submit information to the new OSHA data collection website.
Some of the employer reported data will be posted on the OSHA website after the removal of any PII (Personally Identifiable Information). OSHA believes that these changes will encourage employers to improve safety in the workplace, provide valuable information to various public entities such as other employers, job seekers, and customers, and enable researchers to analyze injury and illness causation data thereby helping employers to eliminate workplace hazards.
OSHA is planning to create a secure website that is expected to be up and running in February 2017. It will allow for the following three methods of data submission:
- Manually into a web form
- By Uploading a CSV (comma-separated values) file
- Via an API (application programming interface)
Anti-Retaliation Protections
In addition to injury and illness tracking changes, the new rule contains anti-retaliation protections that prevent employers from discouraging employees from reporting injuries and illnesses.
The new rule will also ensure that employers inform employees of their right to report injuries and illnesses without fear of retaliation. This can be accomplished by posting the already required OSHA workplace poster.
These anti-retaliation protections went into effect on August 10, 2016. However, OSHA delayed enforcement until December 1, 2016.
Click on the link below to read the Final Rule.
Regulatory Text for Recordkeeping Standard - Part 1904 - [Amended]
Helpful Links
- Globally Harmonized System The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a system for standardizing and harmonizing the classification and labelling of chemicals.
- Hazcomm Standard An update to the Hazard Communication Standard (HCS) which provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets.
- Mass.Gov Right-To-Know Establishes minimum standards and reasonable requirements to protect the health and safety of employees through the communication of information regarding toxix or hazardous substances.
- Occupational Safety & Health Administration (OSHA) Congress created the Occupational Safety and Health Administration (OSHA)* to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance