OSHA’s Improve Tracking of Workplace Injuries and Illnesses Rule is Final

As anticipated, the Occupational Safety and Health Administration (OSHA) rule – Improve Tracking of Workplace Injuries and Illnesses – is final and was published in the May 12 issue of the Federal Register. The final rule includes substantive changes from the proposed rule and some favor employers.

The rule takes effect on January 1, 2017, except for two provisions which become effective August 10, 2016. The exceptions include the provisions on employee involvement and prohibition against discrimination. The enforcement dates are as follows:

• Employers of 250 or More Employees (large employers) will be required to electronically submit to OSHA their 2016 OSHA 300 A Summary information by July 1, 2017. Going forward, large employers will be required to electronically submit to OSHA information from their OSHA 300 Log, OSHA 300 A Summary, and OSHA 301 Incident Report Forms once each year. The 2017 information must be submitted by July 1, 2018. However, starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2.
• Employers of 20 to 249 Employees will be required to electronically submit to OSHA information from their OSHA 300 A Summary once each year. The 2016 information must be submitted by July 1, 2017. The 2017 information must be submitted by July 1, 2018. Starting in 2019 and each year thereafter, the information from the preceding year must be submitted by March 2.
• OSHA State Plan States have six months to adopt the rule or establish another that is similar and at least as stringent.

OSHA Final Recordkeeping Rule