Final Rule Issued to Improve Tracking of Workplace Injuries and Illnesses – July 1, 2018 Deadline

June 27, 2018

The deadline of July 1, 2018, when specific employers must electronically submit information from their 2017 OSHA Form 300A, is quickly approaching.

Companies with 11 or more employees, whose individual establishments (generally single physical locations) are not partially exempt from keeping OSHA injury and illness records (see OSHA Fact Sheet 3746) — and who meet OSHA’s establishment level triggers (250 or more peak employees during 2017 at a location in any industry or 20 or more peak employees in certain “high hazard” industries) — are required to report 300A data for the affected locations. “Employees” in this context include part-time, seasonal and temporary employees supervised on a day-to-day basis.

The injury tracking application can be found on the OSHA ITA website. Once the account has been created, you may enter your data manually into a web form. If you have multiple locations and/or a large amount of data, you may want to upload a CSV file to process single or multiple establishments at the same time.

For further instructions on how to file, go to the OSHA website.

State Plans

OSHA had previously required reporting of location data only for locations in Federally administered and State administered OSHA plans that had adopted the new requirements. Federal OSHA has now asserted that employers in all States, including States that have not adopted the Federal regulation are required to report using the Federal ITA portal. States that initially did not adopt the federal regulation are as below. If you have operations in these states that are required to report, please check the status of your State’s adoption.

• California (Cal/OSHA)
• Washington (WA DLI, WISHA, or DOSH)
• Maryland (MOSH)
• Minnesota (MNOSHA)
• South Carolina (SC OSHA)
• Utah (UOSH)
• Wyoming (WY OSHA)
• Vermont (VOSHA)

More information on the final rule can be found here. We urge you to take this deadline seriously and submit appropriate forms.