Enforcement of OSHA’s electronic reporting requirements in its recently revised recordkeeping rule starts in most states on December 15, 2017. However, some of the OSHA state-plan-states have not yet adopted the requirement to submit recordable workplace injury/illness data electronically. The following OSHA-approved State Plans have not adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY. Establishments in these states are not currently required to submit their summary data through the Injury Tracking Application (ITA). Contact information for each of the State Plans can be found at https://www.osha.gov/dcsp/osp/states.html.
For states that are affected by the revised rule, enforcement dates are as follows.
Enforcement Dates:
Employers of 250 or More Employees (large employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 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 2nd.
Employers of 20 to 249 Employees (small employers) – Electronically submit to OSHA 2016 OSHA 300 A Summary information by December 15, 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 2nd.
Electronic Submittal Information and Portal – Improve Tracking of Workplace Injuries/Illnesses
MCAA Safety Bulletin – Improve Tracking of Workplace Injuries/Illnesses
OSHA Final Rule – Improve Tracking of Workplace Injuries/Illnesses