OSHA Electronic Recordkeeping – Update

Constantly changing dates for submission of data to OSHA’s Injury Tracking Application (ITA) has created confusion for many employers. The deadline for submission of information from the 2018 OSHA 300A form was March 2^nd, 2019, and March 2^nd will remain the deadline for all future, annual submissions. 

Originally, the ITA would not accept data entered after each of the published deadlines. Presumably, this was so OSHA could establish the employers that failed to meet the deadline. I was recently made aware that employers are able to enter data in the ITA, even though we are past the March 2^nd deadline.

I was unable to confirm if the system will accept data from previous years, including 2016 and 2017. OSHA’s technical specialist from their Region 1 office was very helpful. Other OSHA regional offices across the country didn’t even answer my phone calls. I wanted to confirm an employer’s ability to enter data from previous years if they missed the deadline, but all the specialist could direct me to do is submit a service request so OSHA in Washington DC could then submit a help desk ticket to their IT personnel. It seems like help desks are running the world these days! He doesn’t believe data from 2016 and 2017 can be entered.

The technical specialist told me the agency has no appetite to flag, cite, and penalize employers who fail to meet the deadline. To the best of his knowledge, employers have until December 31 to enter data from the previous year OSHA 300A form. Even though this individual’s job is to provide employers with information regarding recordkeeping, the agency is not providing this level of detail to its own staff. The agency is still without a leader as the nomination for Assistant Secretary of Labor – OSHA is still being delayed by congressional committee leadership.

This information should provide some relief to employers who didn’t know about electronic recordkeeping, or who missed the March 2^nd deadline. However, it isn’t very comforting when the employees charged with enforcing the law aren’t provided with the information they need to provide answers to the employers they regulate.

In efforts to simplify compliance with their Electronic Recordkeeping Standard, the agency has simplified aspects of the standard. In summary, the following employers are required to submit information from their OSHA 300A form by March 2^nd of every year:

• Employers with 250 or more employees that are required to maintain OSHA logs must submit information on their 300A form
• Employers with 20 or more employees but fewer than 250 employees at any time during the previous calendar year, and the operation is classified in an industry listed in appendix A – Designated Industries*

* There are few differences in the industries required to report data in the two employer size groups.

The agency no longer requires larger employers to submit information from the OSHA 300 log and every first report of injury form. This will make the data submission effort significantly less time consuming and painful for large employers.

If you are responsible for a business required to submit OSHA 300A information, you still have an opportunity to enter data for 2018. OSHA compliance is key to the success of any safety program.  If you have any questions regarding how or what to report, please contact Horton Safety Consultants.