March 2 Deadline: Updated OSHA Electronic Reporting Requirements
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March 2 Deadline: Updated OSHA Electronic Reporting Requirements

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As the March 2 deadline to electronically report to the Occupational Safety and Health Administration (OSHA) looms, you should be aware of some recent changes to the law. 

As a reminder, the original law mandated that all work-related illness and injury data be electronically submitted to OSHA. The first required submission date was for 2017 data to be submitted by July 1, 2018. There was a second deadline added of December 31, 2018, for those establishments who did not submit in time for the original July 1 date.

Going forward, the information from the prior year is to be electronically submitted by March 2.

For establishments with 250 or more employees, electronic reporting was to include Forms 300, 301, and 300A in the electronic submission. Companies with 20 to 249 employees in certain high-hazard industries were required to submit only Form 300A.

The change impacts those establishments with 250 or more employees as they are now required to submit only their Form 300A. The requirement remains the same for those establishments with 20 to 249 employees in certain high-hazard industries. A complete list of those industries can be found on OSHA’s website here.

OSHA has provided a secure website for online reporting. This can be done via a web form, an uploaded CSV file or with an automated recordkeeping system.

Non-compliance with this requirement can, and has, resulted in fines and penalties. Fines and penalties can be assessed by both OSHA and MIOSHA. 

A few other items you may wish to know about this record-keeping rule:

  • The employee count is based on the highest number of employees the establishment had at any given time during the year, not a total of the employees on staff during the year. In other words, if the most you had working at one time was 18, but you employed a total of 28 different people throughout the year, you are not required to report electronically.
  • If you qualify for the electronic reporting requirement, but had no incidents to report, you must still submit the report with all zeros.
  • No matter the employee count, if there is a workplace death you must report it within 8 hours. An amputation, eye loss or in-patient hospitalization must be reported within 24 hours.

Making the Complex Simple

How do you keep track of OSHA reporting? How do you maintain compliance? How can you streamline this process? Saginaw Bay Underwriters offers a solution to our clients at no cost.

Our platform makes electronic reporting to OSHA simpler by creating the CSV file for you, but can also:

  • Create your workers’ compensation “first report of injury.”
  • Track DART rates, OSHA incident rates, severity rates and lost time case rates.
  • Allow you to track “near misses,” so you can avoid future injures.

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