The Occupational Safety and Health Administration (“OSHA”) recently announced that the deadline requiring certain employers to electronically submit their OSHA injury and illness logs is postponed until December 1, 2017. OSHA delayed this deadline, in part, to finalize its newly launched website, the Injury Tracking Application (“ITA”), through which covered employers will need to submit these logs annually moving forward.
As previously outlined in a Locke Lord webinar and QuickStudy, the electronic recordkeeping rule requires covered employers to electronically submit their injury and illness logs—Forms 300A, 300, and/or 301—to OSHA depending on the size and industry of the employer. These employers now will need to submit the first of these logs (Form 300A) on or before December 1, 2017.
The ITA is a secure website which is currently accessible to employers so they may become familiar with it before the December deadline. To submit their logs, covered employers first have to create an online account. Employers then need to create a profile for each establishment meeting the industry and size reporting criteria. Finally, employers will have three format options to submit their data:
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by manually entering data onto a web form;
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by uploading a CSV file to simultaneously process single or multiple establishments; and
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by transmitting data electronically via an application programming interface (“API”), if the employer uses an automated recordkeeping system.
Employers should continue to assess whether the electronic submission requirements apply to their businesses and utilize the time prior to the submission deadline to establish their accounts and profiles and plan accordingly to meet the applicable submission deadline.
