OSHA: Additional Reporting Requirements On Employers

On May 11, OSHA promulgated a new regulation imposing additional reporting requirements on employers. All non-exempted employers are already require to report information on work related illnesses and injuries to OSHA on paper forms, however, the new rule requires that certain submissions now be made electronically.

The newly promulgated regulation establishes three different categories of employers and imposes different electronic reporting requirements on each. Those non-exempted employers with 250 or more employees at an establishment must electronically submit certain information from the three reporting forms established by OSHA: 1) Form 300 – Log of Work Related Injuries and Illnesses; 2) Form 300A – Summary of Work-Related Injuries and Illnesses; and 3) Form 301 – Injury and Illness Incident Report.

Non-exempted employers with more than 20 employees, but less than 250 employees at an establishment, and who are engaged in a business designated in Appendix to the new rule, are required to electronically file information from Form 300A. Employers in this category include, among others, construction and manufacturing industries and many retail operations, such as department and furniture stores.

Lastly, non-exempt employers with less than 20 employees at an establishment are required to file information electronically when so notified by OSHA.
Those employers required to file information electronically must do so by July 1, 2016, July 1, 2017 and thereafter annually by March 2 of each succeeding year beginning in 2018. The information that must be submitted consists of all information on the three forms, except that the following information may be omitted:

Form 300: Employee name (column B);

Form 301: Employee name (field 1);
Employee address (field 2);
Name of physician or other health care professional (field 6); and
Facility name and address if treatment was given away from the worksite (field 7).