OSHA Update


New Electronic Injury and Illness Data Reporting Rule


By Gary Jones, Assistant Vice President, EHS Affairs, Printing Industries of America


On May 11, 2016, the Occupational Safety and Health Administration (OSHA) released its new recordkeeping rule requiring employers to submit injury and illness data annually, begin- ning in July 2017. The rule, Improve Tracking of Workplace Injuries


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and Illnesses, has two components. The first com- ponent requires companies to submit records of workplace injuries and illnesses electronically to OSHA. The second component prohibits retaliation against employees who report workplace injuries or illnesses.


This controversial rule resulted in legal challenges to its validity by industry groups. As a result, OSHA delayed implementation of the anti-retaliation pro- visions and issued additional guidance on several provisions in the rule, which can be found at http://prnt.in/2016osharule. Since the federal court in Texas did not enjoin the rule, it became effective on December 1, 2016. The two lawsuits are still active, and a court has not ruled on the merits of the rule.


Electronic Submission Requirements The rule requires certain employers, including print- ing operations, to electronically submit


Recordkeeping Forms for Year


2016 2017


2018 and thereaſter


the injury and illness information to OSHA. The requirement applies to the following:


• Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records


• Establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses


Data submission requirements for these businesses will be phased in according to Chart 1.


OSHA will remove personally identifiable informa- tion and then post the establishment-specific injury and illness data it collects on its website at www.osha.gov.


Informing Employees about Injury Reporting and Anti-Retaliation While not in the rule itself, OSHA’s preamble explanation of the rule states that an employer must provide reasonable procedures for reporting work-related injuries and illnesses that do not deter or discourage employees from reporting them.


According to OSHA, informing employees about their right to report injuries can be met by posting the OSHA Job Safety and Health — It’s The Law poster


New Electronic Form and Submission Requirements


Establishments* with 250+ Employees


Form 300A


Form 300 Log, Form 300A & Form 301


Form 300 Log, Form 300A & Form 301


Establishments* with 20–249 Employees


Form 300A Form 300A


Form 300A


Chart 1. New electronic form and date submission requirements *Establishment means a single location and not a total company enrollment amount.


Deadline to Submit Form


July 1, 2017 July 1, 2018


March 2, 2019


OPERATIONS


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