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What will my company have to do to adapt to the new electronic submission requirements from OSHA's Final Rule?

Q:

Because of OSHA's new Final Rule, my company will have to start reporting our injury and illness information electronically. What will we have to do to make sure we're submitting properly and staying compliant?

A:

First of all, let’s take a quick look at what OSHA’s final rule requires of businesses. As of January 1, 2017, some employers have had to electronically submit the injury and illness data they already recorded on paper forms. The goal is to allow OSHA to analyze data more easily and use its resources more efficiently, as well as to encourage employees to report any and all work-related injuries or illnesses. The data will be compiled and made publicly available.

Perhaps your business doesn’t currently use software to track your injury and illness data, or maybe you’re not technologically inclined. Worry not. OSHA provides several ways for you to submit your records electronically without needing to purchase expensive software.

Businesses that need to report data must use OSHA’s secure website. From there, you have three options:

  1. Manually enter your data into a webform for submission
  2. If your data is in a spreadsheet, you can upload a CSV file
  3. If you maintain automated recordkeeping, you can submit your data via an application programming interface (API)

To be in full compliance with OSHA’s final rule, businesses have to inform employees of their right and responsibility to report all workplace incidents. Employers also have to establish reasonable procedures for employees to report work-related injuries and illnesses. That is, procedures that would not deter or discourage an employee from filing a report.

Now, what data do you need to submit and when? The reporting requirements differ depending on your business:

Submission Year

Establishments with

250 or more employees

Establishments with

20-249 employees

Submission Deadline

2016

Form 300A

Form 300A

July 1, 2017

2017

Forms 300A, 300, 301

Form 300A

July 1, 2018

From 2019 onward, all required information must be submitted electronically to OSHA by March 2nd of each year.

If your business is already keeping accurate records and encouraging employees to report all workplace injuries and illnesses, this rule really has little consequence. Your next step is to determine the best way for you to submit your data online—whether it’s manually inputting the information, uploading a CSV file, or via API.

Regardless of how you decide to track this critical information, I recommend you review your reporting procedures and determine the best way to maintain a reliable record of your workplace injury and illness information going forward.

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Written by Adrian Bartha
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Adrian Bartha is the CEO of eCompliance, which he joined in 2012 after experiencing first-hand how a workplace incident affected a power and utilities company which he led as a member of the Board of Directors. Previously, Adrian was an investment professional for a $5 billion dollar private equity firm investing in energy, construction, and transportation infrastructure companies across North America. When Adrian is out of the office, he can be found riding his futuristic motorcycle and wearing his RoboCop helmet.   Full Bio