OSHA to Expand Your Injury Reporting Requirements and Make Information Public

OSHA already requires most businesses to keep records of work-related injuries and illnesses through Form 300A — Summary of Work Related Injuries and Illnesses, Form 300 — Log of Work-Related Injuries and Illnesses and Form 301 — Injury and Illness Incident Report. But now the agency has taken this a step further with a new recordkeeping and reporting rule designed to “modernize injury data collection to better inform workers, employers, the public and OSHA about workplace hazards.”

The new rule, issued May 11, 2016, will require certain employers to send their injury and illness data to OSHA, who will then post the information on the agency’s website. Anyone can visit the public database for details on work injuries throughout the United States.

Be certain your workplace is committed to safety and complying with OSHA’s recordkeeping requirements.

The electronic submission requirements take effect January 1, 2017, but they will be phased in over two years as follows:

By July 1, 2017

• Businesses with 250 or more employees in an industry that’s already required to keep OSHA injury and illness records — and businesses with 20-249 employees and in a high-risk industry — must electronically submit 2016 information from Form 300A-Summary of Work-Related Injuries and Illnesses.

By July 1, 2018

• Businesses with 250 or more employees must electronically submit 2017 information from all three OSHA forms: Form 300 — Log of Work-Related Injuries and Illnesses, Form 300A — Summary of Work-Related Injuries and Illnesses, and Form 301 — Injury and Illness Incident Report. Businesses with 20-249 employees must electronically submit 2017 information only from Form 300A — Summary of Work-Related Injuries and Illnesses.

Beginning in 2019 and every year thereafter

• Applicable injury and illness information must be submitted by March 2.

What to Do Next to Comply with Newest OSHA Rule

Why the new rule? OSHA hopes that by making injury information available publicly, employers will take workplace safety that much more seriously. The rule also supports accurate and complete reporting of work-related injuries and illnesses by encouraging employers to:

1. Inform employees of their right to report incidents without retaliation (see below)
2. Create reasonable procedures for employees to report incidents that don’t discourage or deter
3. Not retaliate against employees for reporting injuries and illnesses

Be certain your workplace is committed to safety and complying with OSHA’s recordkeeping requirements. In preparation of the upcoming new rule, you should:

• Make sure you are posting the OSHA Job Safety and Health — It’s the Law federal poster from April 2015 to comply with the new OSHA notification requirement to inform employees of their right to report work-related injuries free from retaliation
• Review your injury reporting procedures and make any necessary adjustments
• Revisit the proper reporting procedures and how to complete OSHA Forms 300, 300A and 301 at Injury & Illness Reporting