By Dan Parks, ABCWI Safety Manager

OSHA’s revised record keeping rules require certain high-risk establishments with 20 or more employees at each facility or business location to electronically file their injury and illness records on line. Since the construction industry falls under the high-risk category, ABC of WI would like to remind members that OSHA’s December 1st deadline for electronic submissions of injury and illness records is approaching. For those who aren’t familiar with these requirements, OSHA has posted the following information to help clarify who falls under the new regulation, what companies must submit, when the requirements will be phased in over the next few years and how to submit. See below:

Who: 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 certain industries with historically high rates of occupational injuries and yet adopted the requirement to submit injury and illness reports electronically: https://www.osha.gov/injuryreporting/ita/
Note: Construction would fall under the “certain industries” comment above. There are historically high rates of injuries and illnesses in construction.

What: Covered establishments with 250 or more employees must electronically submit information from 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.
Note: If a company has multiple locations, only the locations with 20 or more employees would have to electronically file. 

When: The requirement becomes effective on January 1, 2017. The new reporting requirements will be phased in over two years. In 2017, all covered establishments must submit information from their completed 2016 Form 300A. In 2018, covered establishments with 250 or more employees must submit information from all completed 2017 forms (300A, 300, and 301) by July 1, 2018, and covered establishments with 20-249 employees must submit information from their completed 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.

How: OSHA will provide a secure website that offers three options for data submission. First, users will be able to manually enter data into a web form. Second, users will be able to upload a CSV file to process single or multiple establishments at the same time. Last, users of automated record keeping systems will have the ability to transmit data electronically via an API (application programming interface). We will provide status updates and related information here as it becomes available.