OSHA’s Electronic Record Keeping Rule can become one of the greatest headaches for business owners each year if they are not diligent in their record keeping or staying persistent with all OSHA requirements. OSHA is constantly trying to meet organization and employee needs by changing policies and regulations to make for smoother operations.
One of the most recent changes that will have a big impact on organizations is the new electronic submission deadline. Previously, the due date for electronic submissions of OSHA 300A Logs was July 1st, but beginning in 2019, and each year thereafter, the submission due date will be March 2nd.
(NOTE: See under Compliance Schedule information related to this change in filing deadline).
A simple internet search will likely show the old due date for electronic reporting because OSHA has not made many mentions of the new date. As fact, this new date is listed in last sentence of last paragraph on Compliance Schedule page stating, “Establishments with 20-249 employees in certain high-risk industries must submit information from their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.”
Not all organizations are required to track work-related employee injuries and illnesses, but organizations with more than 10 employees in high risk industries are required to record all incidents and illnesses on 300A logs. Organizations with more than 20 employees are required to not only record all incidents and illnesses on 300A logs, but also electronically submit this report annually to OSHA by the new March 2 filing deadline. To see if your organization is exempt from OSHA reporting look for your NAICS code on the Partially Exempt Industries List.
It is important to remember that if an organization is covered under OSHA, but exempt from reporting all incidents and illnesses, they are still required to report any work-related hospitalizations, amputations or eye losses within 24 hours of the incident. FATALITIES MUST BE REPORTED WITHIN EIGHT (8) HOURS OF THE INCIDENT.
Keep in mind that when filing your organization’s 300A Logs you should have a log for each legal business entity that your organization has established. The 300A Log must be reviewed by someone other than the person who created the report to ensure accuracy and also must get signed off by an executive of the organization.
The deadline for organizations to post their OSHA 300A Log for all employees to view is February 1st each year.
OSHA’s secure website for reporting allows three different types of OSHA 300A submissions. The first option allows an establishment to manually enter each incident and illness. The second option allows an establishment to “batch upload CSV files” one at a time or multiples at once. The third option allows any establishment that uses an automated recordkeeping system to transfer data electronically by using an API (Application Programming Interface).
SMART Safety Group is both knowledgeable and proficient in the management and electronic filing of OSHA 300A reports. To learn how SMART Safety can help your organization visit our Safety Program Management page.
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