Because of government postponements, a change in presidential administrations and a lack of publicity, there has been much confusion about when and who needs to meet OSHA’s new requirement for electronically filing worker injury and illness data by Dec. 1.
As of this date, employers are being told they must take the information they already fill out regarding worker accidents and also file it electronically. Many Michigan employers will fall under this rule.
OSHA says these businesses fall under the new guideline:
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).
Establishments with 20-249 employees in certain high-risk industries must electronically submit to OSHA some of the information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A).
Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA.
There has also been talk of a July 1, 2018 electronic filing deadline as well, but a MIOSHA official said they are waiting for guidance.
Electronic filing does NOT replace the requirement to also keep paper copies on file.
Here are a couple helpful links about the electronic filing requirement; copy and paste in your browser:
• See if your industry is affected: bit.ly/OSHAfaq (click on the question “Who must submit information electronically to OSHA under the final rule?” It provides the above description but also a link to the high-risk industries)
• More information here: bit.ly/OSHAreg
If you’re still unsure, contact OSHA at 800-321-6742, or MIOSHA at 517-284-7788 for record-keeping questions.
