The deadline for electronic submission of 2016 Form 300A data has been delayed. On November 24th, OSHA issued a notice extending the Recordkeeping deadline from December 1st to December 15th, 2017.
This extension comes after a temporary shutdown of the agency’s Injury Tracking Application (ITA) due to concerns, from the United States Computer Emergency Readiness Team (US-CERT), of a potential compromise of user information. After a complete scan by the National Information Technology Center (NITC), it was determined that there was no breach of ITA data and no information was compromised. On August 25th, public access to the ITA was restored.
OSHA’s reasoning for deadline extension is to compensate for the time employers were unable to access the ITA in August, thus providing the originally intended four-month window to submit data.
While this extension was controversial among industry professionals who called for even more time to submit their Form 300A data, OSHA publicly disagreed with these commenters. However, OSHA did reiterate its intention to “issue a separate proposal to reconsider, revise, or remove other provisions of the prior final rule and to seek comment on those provision in that separate proposal.”
Recap of OSHA’s Electronic Submission of Injury and Illness Records
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 illnesses.
Exceptions: The following OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY.
Similarly, state and local government establishments in IL, ME, NJ, and NY are not currently required to submit their data through the ITA.
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.
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 recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface).
For more information, visit OSHA’s Webpage.To find out more about this topic, click here.