With the February 1st OSHA posting date looming, many employers who have heard about electronic OSHA reporting requirements are unsure about whether they are affected and if the new rule affects their current OSHA recordkeeping obligations. Some frequently asked questions about these requirements include:
Who has to report electronically and when?
Electronic reporting of OSHA illness & injury data will be required for:
- Establishments with 250 or more employees
- Establishments in certain high-risk industries with 20 – 249 employees.
Deadlines for electronic submission:
- July 1, 2017, for 2016 calendar year data
- July 1, 2018, for 2017 calendar year data.
- Beginning 2019, the target date shifts to March 2nd.
Does the rule require that my company start keeping new records or to change how we currently keep OSHA records?
No. The new requirement does not add to or change an OSHA’s regulations regarding an employer’s obligation to complete, retain, and certify injury and illness records. It only requires certain employers to electronically submit some of the information from these records to OSHA.
Are the electronic reporting requirements based on the numbers of employees in my company or the numbers of employees at each location (e.g. establishment)?
The existing OSHA recordkeeping requirements are based on the total company size (11 or more employees at any time during the calendar year). However, the new electronic reporting requirements are based on the size of the establishment, not the company. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed.
The OSHA website (www.OSHA.gov) is a great resource for commonly asked questions. The Flanders Group is a full service agency offering workers compensation, commercial lines, health and benefits. Call us at 800-462-6435.
Executive Vice President