OSHA Delays Electronic Reporting to Dec. 15, 2017 

The Occupational Safety and Health Administration’s (OSHA) electronic reporting rule requires certain establishments to report information electronically from their OSHA Forms 300, 300A and 301

By: Rob Foote, Roofing Risk Advisors, LLC.

Under the rule, the first electronic reports were due on July 1, 2017; however, on Nov. 24, 2017, OSHA issued a new final rule officially delaying the first electronic reporting deadline to Dec. 15, 2017. Affected establishments will need to submit their reports through the Injury Tracking Application (ITA) website by that time or face possible OSHA penalties.

Action Steps

• Affected establishments must create an account on the ITA website and submit information from their 2016 OSHA 300A form by Dec. 15, 2017.
• Other deadlines under the electronic reporting rule remain unaltered. Therefore, affected establishments should begin their preparations to submit information from all 2017 OSHA forms by July 1, 2018.

Affected Establishments OSHA’s electronic reporting rule affects establishments that:

• Are already required to create and maintain OSHA injury and illness records and have 250 or more employees;
• Have between 20 and 249 employees and belong to a high-risk industry; and
• Receive a specific request from OSHA to create, maintain and submit electronic records, even if they would otherwise be exempt from OSHA recordkeeping requirements./li>

The electronic reporting rule applies to establishments, not employers. An employer may have several worksites or establishments. In these situations, some establishments may be affected while others are not.

To determine whether an establishment is affected, employers must determine each establishment’s peak employment during the calendar year. During this determination, employers must count every individual that worked at that establishment, regardless of whether he or she worked full-time, part-time, or was a temporary or seasonal worker.

Finally, a firm with more than one establishment may submit establishment-specific data for multiple establishments.

Reporting Requirements The data an employer must submit and the timeline for submitting this information to OSHA depends on the establishment size. Establishments with 250 or more employees will be required to submit information from their OSHA Forms 300A, 300 and 301. However, in 2017, these establishments will only be required to submit data from their 300A Form. Establishments in high-risk industries with between 20 and 249 employees will be required to submit information only from their OSHA Form 300A

For the first reporting year, the deadline has been delayed to Dec. 15, 2017. However, the final rule that delayed the first deadline did not alter subsequent deadlines, so reporting deadlines for 2018, 2019 and beyond remain as shown in the table below.

Submitting the Report The ITA is a secure website that OSHA created specifically for the data required by the electronic reporting rule. The ITA allows employers three options to submit their reports:

1. Manual entry;
2. Comma-separated value (CSV) file upload; and
3. Application programming interface (API) transmission.

The ITA offers affected establishment instructions and sample files and templates to help them complete the submission process.

Contact Roofing Risk Advisors a division of Frank H. Furman, Inc. for more information regarding electronic reporting or filing.<