OSHA Electronic Reporting
The provisions of the Final Rule on recordkeeping require specified employers to electronically submit data that has historically been maintained in hard copy format at the business’ location. Specifically:
• No later than July 1, 2017, establishments with 250 or more employees that are subject to OSHA’s recordkeeping regulation must electronically submit to OSHA some of the information from the Log of Work-Related Injuries and Illnesses (OSHA Form 300), the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and the Injury and Illness Incident Report (OSHA Form 301).
• No later than July 1, 2017, establishments with 20-249 employees in designated high-risk industries (based on NAICS industry code) must electronically submit to OSHA some of the information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A). The Final Rule and the NAIS codes are not completely clear, but it looks like equipment dealers (especially with repair departments, which covers most dealers) are covered.
• Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA. Other employers may be directed to report electronically by OSHA.
Iowa OSHA has adopted these provisions of the Final Rule. Iowa OSHA does not plan to have a separate state website for reporting, rather, the expectation is that there will be one federal website but the details are still being worked out.
EEO-1 Report and Pay Data
Dealers with 100 or more employees will need to collect pay data in 2017 for new reporting requirements on the revised EEO-1 report. The revised EEO-1 will require employers to report W-2 earnings data and total hours worked in 12 pay bands for each of 10 job categories and 14 gender, race and ethnicity catego- ries. The revised EEO-1 report will require covered dealers to collect pay data from September 30, 2017 to March 31, 2018, and will be due on March 31, 2018.
Dealers with EEO-1 reporting obligations should evaluate their current information systems to determine how the necessary pay data can be best collected. Dealers must be aware that any wage disparities among gender, race, or ethnicity that appear from the pay data may be grounds for a discrimination claim. Conse- quently, dealers might want to have an attorney conduct an internal audit of their pay data well in advance of September 30, 2017, to determine whether potential liability exists.
If you have questions or concerns about these updates or any other labor or employment matter, call the INEDA Human Resource Helpline toll-free at (855) 277-5575.
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