The July 1, 2018 deadline for large employers (250+ employees at a single work site) and smaller employers (20-249 employees) in certain so-called “high hazard industries” to submit injury and illness data to OSHA is less than a week away. We have been tracking closely the Trump Administration’s treatment of OSHA’s new E-Recordkeeping and Anti-Retaliation Rule, and while there have been plenty of signals that this rule is due for an overhaul, it appears that this deadline for the second data submission under the rule is going to stand.
Therefore, if employers have not already done so, they should immediately evaluate whether the rule applies to any or all of their workplaces, get familiar with and set up an account in OSHA’s Injury Tracking Application (the portal that will receive the injury data), and submit covered injury data (i.e., their 2017 OSHA 300A Annual Summary data) by this Sunday.
For a last-minute primer on the nuances of OSHA’s E-Recordkeeping Rule, check out this blog article from Intelex, a compliance software development resource. Here is the opening excerpt from the article:
“Mandatory submission of injury and illness data to OSHA through a dedicated Web-based portal should, in theory, make the process quick and easy. However, a recent spate of real and proposed changes to the agency’s E-Recordkeeping Rule has left many employers wondering if they are required to submit injury and illness data for certain establishments, by when they must do it, and what the consequences are of not submitting the data.
The latest in Conn Maciel Carey LLP’s OSHA webinar series addressed these topics and provided some much-needed clarity for employers.”
For more information about OSHA’s E-Recordkeeping Rule, here is a link to a series of articles and webinar recordings about the rule that we have posted previously here on the OSHA Defense Report blog.