Thank you to my colleague, Diana Neeves, for this post.  Diana is an associate in our Environmental & Utilities Practice Group.

As we outlined last year, OSHA recently revised its recording and reporting regulation to require certain employers to submit injury and illness data to OSHA on an annual basis for posting on OSHA’s website.  The deadline for the submission of 2016 data, which was originally scheduled for July 1, 2017 and later extended to December 15, 2017, is fast approaching.

OSHA regulations have long required establishments covered under 29 C.F.R. Part 1904 to keep a “Log of Workplace-Related Injuries and Illnesses” (Form 300), an “Injury and Illness Incident Report” (Form 301), and an annual “Summary of Work-Related Injuries and Illnesses (Form 300A).  Under the new reporting requirements, covered establishments with more than 250 employees must submit the three forms (300, 301, and 300A) to OSHA’s electronic database, the Injury Tracking Application (ITA).  Additionally, covered establishments in certain industries with 20-249 employees are required to submit Form 300A to the ITA.

As stated above, the deadline for submission of 2016 data is next week – December 15, 2017.  Next year, the covered establishments will be required to submit their 2017 data by July 1, 2018.  Starting in 2019, the deadline for submission of a previous year’s data will be March 2 of the following calendar year.

Note that not all State Plans have been updated to reflect these new reporting requirements.  Therefore, electronic disclosure is not yet required for establishments in California, Maryland, Minnesota, South Carolina, Utah, Washington, and West Virginia.  Likewise, electronic disclosure is not required for state and local government establishments in Illinois, Maine, New Jersey, and New York.  More information on individual State Plans is available here.

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