Earlier this week, the Michigan Occupational Safety and Health Administration (MIOSHA) amended its existing administrative standard concerning covered employers’ recording and reporting of occupational injuries and illnesses. The purpose of the amendment was to align the standard with federal OSHA’s new reporting requirements that went into effect on Jan. 1.
Under MIOSHA’s amended standard, which can be found here, certain Michigan employers must, on an annual basis, electronically provide federal OSHA (or its designee) detailed information about each recordable injury and illness entered on their previous year’s MIOSHA or OSHA Forms 300 and 301. Specifically, Michigan employers with this new reporting obligation include those who (a) had 100 or more employees at any time during the previous calendar year and (b) are part of a high-hazard industry, as identified in Appendix C of the new standard. The amended standard identifies a broad range of industries that include, without limitation, certain farming operations, the automotive industry, nursing care facilities and other health care organizations.
Concerning the recordable injury and illness data that must be submitted under the amended standard, this includes the date, physical location and severity of the injury or illness; details about the worker who was injured (excluding the worker’s name); and details about how the injury or illness occurred.
The amended standard does not impact other posting or reporting obligations concerning covered employers’ MIOSHA or OSHA Form 300A, which Warner attorneys Steve Palazzolo and DeAndre’ Harris discussed during a Law Shanty last year. Like Form 300A, data required by the amended standard must be submitted to federal OSHA’s Injury Tracking Application no later than March 2 of each calendar year.
