OSHA Rolls Back Reporting Requirements

February 2019

In a welcome development for employers, the Occupational Safety and Health Administration (OSHA) has eliminated its requirement that larger employers must electronically submit records to OSHA tracking each on-the-job injury or illness. Employers must still keep the records on site, however. In a press release, OSHA stated that it eliminated the electronic submission requirement in order to safeguard workers’ privacy by “avoiding the risk that [workers’ personal] information might be publicly disclosed” and by protecting “personally identifiable information or data that could be re-identified with a particular worker.”

Under OSHA’s recordkeeping requirements, employers must log employees’ on-the-job injury and illness data into three forms: Form 300, Form 300A, and Form 301. Form 300 is a running log of each injury or illness that occurs at a particular establishment during the year. Form 300A is a non-detailed summary of work-related injuries and illnesses that is compiled at the end of each year. Form 301 is an “Injury and Illness Incident Report” that explains the circumstances surrounding each injury or illness in order to help the employer and OSHA better understand the extent and severity of the work-related incident. 

Historically, these forms were simply maintained by employers and provided to OSHA upon request. But in May 2016, OSHA began requiring establishments with 250 or more employees to electronically submit all three forms annually. The rule also required establishments with 20 to 249 employees in certain hazardous industries to submit Form 300A to OSHA annually.

Reversing course, OSHA will no longer require electronic submission of the 300 Logs or 301 Incident Reports, effective February 25, 2019. The new rule only retains the obligation to annually upload the Form 300A summary – which contains no employee-identifying information.

The full text of the rule may be found here.

If you have any questions about your company’s OSHA reporting obligations, please contact a Lewis Rice labor and employment attorney.

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