ThinkHR previously reported (Are You Ready to Electronically Report Injuries and Illnesses to OSHA) that December 1, 2017, was the deadline for certain employers to use the Occupational Safety and Health Agency’s (OSHA) Injury Tracking Application (ITA) portal to report information from their 2016 Form 300A regarding employee illnesses and injuries. However, on November 22, 2017, OSHA announced that it is extending the deadline by two weeks. The new deadline for impacted employers to complete reporting is December 15, 2017.
OSHA also announced that it is currently reviewing other provisions in the final electronic reporting rule and intends to publish a notice of proposed rulemaking to reconsider, revise, or remove portions of that rule in 2018.
Impacted employers are encouraged to review electronic reporting requirements and complete the online reporting process. Below is a summary of certain requirements under the rule.
Who must comply with the December 15, 2017 deadline?
- Most establishments with 250 or more employees that are currently required to keep OSHA injury and illness records.
- Employers with 20-249 employees from certain industries with historically high rates of occupational injuries (high-risk industries) and illnesses.
Are all employers falling in the above categories required to submit their reports through the ITA portal?
No. Some states with OSHA-approved state plans have not yet adopted a requirement that illness and injury reports be submitted electronically. Establishments in the following states are currently not required to submit their reports using the ITA portal:
- South Carolina
Establishments in these states may contact their state plan for more information about reporting requirements.
Additionally, state and local government establishments in the following states with OSHA-approved state programs have not adopted OSHA’s final rule requiring electronic reporting of illness and injury and are not required to submit their reports through the electronic portal:
- New Jersey
- New York
Where can I find information about how to complete the electronic submission process?
OSHA’s ITA portal offers three options for submitting data. Employers can manually enter data on the site, upload a comma separated values (CSV) file into the ITA portal, or transmit records electronically from an automated recordkeeping system using an application programming interface (API). OSHA offers instructions for both the CSV and API processes as well as frequently asked questions related to the reporting process.
How much time will it take to complete the electronic reporting process?
For employers with 20-249 employees who are required to report, OHSA estimates that it will take approximately 20 minutes to complete the reporting process. OSHA estimates it will take 32 minutes to complete the reporting process for impacted employers with 250 or more employees. Additional reporting requirements will be rolled out over the next two years for impacted employers.
ThinkHR will continue to monitor developments in this area.