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Labor and Employment Alert: OSHA Extends the Deadline for Electronic Submission of Injury Reports to December 15, 2017

Last year, the federal Occupational Safety and Health Administration (OSHA) amended its recordkeeping rules related to workplace injuries and illnesses to require employers keeping those records to submit information to OSHA electronically. OSHA, in turn, will post that information on its public website, with the idea of shaming employers with poor safety records. OSHA has extended the deadline for employers to submit their electronic injury and illness reports (from OSHA Form 300A) through the new Injury Tracking Application to December 15, 2017.

Generally establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in industries with historically high rates of injuries and illnesses, are required to submit these reports. However, establishments in California, Maryland, Minnesota, South Carolina, Utah, Washington and Wyoming are not currently required to submit their summary data through the Injury Tracking Application.

Covered establishments with 250 or more employees must electronically submit their 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). Covered establishments with 20-249 employees must electronically submit information from OSHA Form 300A. Looking ahead to 2018, covered establishments with 250 or more employees must submit information from Forms 300A, 300, and 301 for 2017 by July 1, 2018. Covered establishments with 20-249 employees must submit information from their Form 300A for 2017 by July 1, 2018.

Contact your Vorys lawyer if you have questions about any of these reports or other aspects of OSHA compliance.

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