The new rule took effect Jan. 1 of this year and requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. Some of the data will also be posted to the OSHA website. OSHA believes that public disclosure will encourage employers to improve workplace safety and provide valuable information to workers, job seekers, customers, researchers and the general public.
Who is affected?
Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
In Michigan, covered employers have until December 1 to comply. **OSHA has extended the deadline until December 15, 2017***
What do you need to do?
For 2017, you’ll need the data from your 300A summary page – information such as the average number of employees, total hours worked, and your North American Industry Classification System code (NAICS).
Go to the OSHA Injury Tracking Application page and set up your business account. Once registered, you’ll receive an email with a link that directs you to the page where you’ll enter your 300A summary data.
- Be sure to have the appropriate Michigan safety and health poster displayed in your facility.
- Posting this poster helps to satisfy OSHA’s anti-retaliation requirement that is specifically written into the new rules.
- The new rule also clarifies the existing implicit requirement that an employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting.
- Many people ask about policies on drug testing following an injury. The rule does not prohibit drug testing of employees. It only prohibits employers from using drug testing, or the threat of drug testing, as a form of retaliation against employees who report injuries or illnesses. If an employer conducts drug testing to comply with the requirements of a state or federal law or regulation (such as DOT), the employer's motive would not be retaliatory and this rule would not prohibit such testing.
HR Collaborative has professional resources available to help walk you through the reporting process and answer any questions that you may have.