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Federal Contractors Updates

OSHA Finalizes Electronic Recordkeeping

03/07/19

Author: ADP Admin/Monday, March 4, 2019/Categories: Federal Compliance Update

OSHA Finalizes Electronic Recordkeeping Requirement Overview: The Occupational Safety and Health Administration (OSHA) has issued a final rule that eliminates the requirement for employers with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) to OSHA each year. The final rule takes effect on February 25, 2019.

Effective Date: May 20, 2019

Details:
Background
Generally, employers with more than 10 employees must keep records of work-related injuries and illnesses, unless they are classified under one of the partially exempt low-hazard industries.

In 2016, OSHA published a final rule that requires certain employers to file OSHA recordkeeping forms electronically. Under that rule, employers with 250 or more employees had to submit information from Forms 300, 300A, and 301 to OSHA electronically on an annual basis. Employers with 20 to 249 employees in certain designated industries must submit information from Form 300A to OSHA electronically on an annual basis.

New Rule:
In order to protect worker privacy, OSHA eliminated the requirement for employers with 250 or more employees to submit information from Forms 300 and 301 to OSHA electronically on an annual basis. These establishments will continue to be required to maintain those records on-site, and OSHA will continue to obtain them as needed through inspections and enforcement actions.

Note: Employers with 250 or more employees (as well as those with 20 to 249 employees in certain designated industries) are still required to electronically submit information from OSHA Form 300A. In the new rule, OSHA also amends the recordkeeping regulation to require covered employers to electronically submit their Employer Identification Number (EIN) with their information from Form 300A.

Action Required: Employers covered by OSHA’s recordkeeping requirements should ensure that they meet the requirements outlined above. 

Please contact your dedicated service professional with any questions.

This content provides practical information concerning the subject matter covered and is provided with the understanding that ADP is not rendering legal advice.

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