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OSHA: July 1, 2018 Was the Deadline for Certain Employers to Electronically Submit Form 300A

Posted Tuesday, July 10, 2018 6:26 am

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) requires certain employers to submit the Summary of Work-Related Injuries and Illnesses (Form 300A) in an electronic format.  Even though Hawaii has its own Occupational Safety and Health Division, known as HIOSH, covered Hawaii employers must still comply with the electronic reporting requirement for Form 300A.[1]

Who Must Comply?  Establishments with 250 or more employees, and establishments with 20-249 employees in certain industries with historically high rates of occupational injuries and illnesses were required to comply with this electronic submission requirement, the initial deadline for which was July 1, 2018. 

Can I Submit Form 300A After July 1, 2018?  Covered establishments that failed to submit their completed 2017 Form 300A by July 1, 2018 may continue to submit the data, but it will be flagged as “late.”

How does electronic submission for Form 300A work?  There are three (3) ways a covered establishment may electronically submit the data:

  1. Manually enter data into a webform.
  2. Upload a CSV file to process single or multiple establishments at the same time.
  3. Users of automated recordkeeping systems may transmit data electronically via an application programming interface. The Injury Tracking Application (ITA) is accessible from the ITA launch page.

Must I Electronically Submit Form 300 and Form 301?  Although current regulations (29 CFR § 1904.41) require certain employers to electronically submit the Log of Work-Related Injuries and Illnesses (OSHA Form 300) and the Injury and Illness Incident Report (OSHA Form 301), OSHA is not currently enforcing the electronic submission requirements for Forms 300 and 301.  This is because OSHA intends to issue a proposal to remove the electronic submission requirements for Forms 300 and 301. 

 

[1] On April 30, 2018, OSHA announced that all affected employers must electronically submit their injury and illness data even if the employers are covered by a State Plan that has not completed adoption of their own state rule.

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