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Correction to Electronic Recordkeeping Rule: Electronically Submit Form 300A by July 1

Monday, April 30, 2018

After a review of its 2016 final rule known as the electronic recordkeeping rule, OSHA has made a correction to an implementation error affecting compliance obligations of employers in state-plan states (CA, MD, MN, SC, UT, WA and WY). OSHA decided that Section 18(c)(7) of the Occupational Safety and Health Act, and relevant OSHA regulations pertaining to State Plans, require all affected employers to submit injury and illness data in OSHA’s Injury Tracking Application (ITA) portal, even if the employer is covered by a State Plan that has not completed adoption of its own state rule.

Prior to this correction, employers in states that had not yet completed implementation of the electronic recordkeeping rule were not required to submit their data electronically until the state adopted the rule. Now, all employers in all states that are covered under electronic recordkeeping requirements must electronically submit injury and illness data for calendar year 2017 by July 1, 2018.

Who is required to submit Form 300A data to OSHA electronically?

-          Establishments with 250 or more employees

-          Establishments with 20-249 employees in designated high-hazard industries

For more information, please see the OSHA Electronic Recordkeeping Website.

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