OSHA Corrects Electronic Reporting Implementation – Employers in State Plan States Must Electronically Report Form 300A


All Employers of 20-249 Employees in Specified Industries


July 1, 2018


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The U.S. Department of Labor (“DOL”) recently reviewed implementation of OSHA’s “Improve Tracking of Workplace Injuries and Illnesses” regulation.  The DOL determined that, under the Rule, affected employers are required to submit injury and illness data via OSHA’s Injury Tracking Application (“ITA”) online portal, even if the employer is covered by a state plan that has not yet completed its adoption of their own state rule.

“State Plan” refers to a job safety and health program administered by individual states.  OSHA allows states to create and administer their own programs so long as they meet minimum federal requirements.  Numerous states and jurisdictions administer their own State Plans, and may include expanded health and safety requirements beyond federal OSHA.  Until now, employers could simply comply with the reporting requirements of their State Plan, some of which had not yet implemented electronic reporting.  However, the DOL’s review and determination of the electronic reporting Rule now clarifies that employers in State Plan states must still comply with federal Form 300A reporting requirements.

OSHA has notified State Plan administrations that all employers under state plans must comply with OSHA’s electronic reporting requirement.  In areas where the State Plan has not adopted its own rule, employers must electronically submit Form 300A data for calendar year 2017 by July 1, 2018.  This Rule covers employers of 20-249 employees in specified high-risk industries. Employers should prepare to meet the required reporting deadline.

Action Items

  1. Employers can access the ITA portal and learn more about electronic submission of injury and illness records on the DOL’s dedicated webpage.
  2. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser.

© 2018 ManagEase

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