Overview: December 1, 2017 is the proposed deadline for affected employers to electronically submit injury and illness records to the Occupational Safety and Health Administration (OSHA). OSHA may still change the requirements in the final rule; however, affected employers should prepare to meet the proposed deadline. OSHA has set up a website, called the Injury Tracking Application (ITA), for affected employers to electronically submit their data.
Effective Date: December 1, 2017 is the proposed deadline for affected employers to submit 2016 injury and illness records via the OSHA ITA.
Action Required: Affected employers should prepare to submit the data from their 2016 OSHA 300A via the OSHA ITA by December 1, 2017.
Employers affected by the new electronic submission requirements fall into three categories. Category 1 is employers with 250 or more employees at any time during the previous calendar year and is not partially exempt based on their industry. Category 2 is employers that had between 20 and 249 employees at any time during the previous calendar year and are included in OSHA listing of certain high-risk industries. Category 3 is employers that are notified by OSHA, the Bureau of Labor Statistics, or a state agency that they are affected.
In the July 6, 2017 edition of the Insights & Solutions newsletter, we informed you that, in a Notice of Proposed Rulemaking published on June 28, 2017, the Occupational Safety and Health Administration (OSHA) proposed to postpone the deadline for affected employers to electronically submit injury and illness records from July 1, 2017 to December 1, 2017. OSHA is currently reviewing the proposed rule and has not yet confirmed the proposed deadline. However, with the December 1 deadline approaching quickly, affected employers should prepare to meet the proposed deadline. OSHA has set up a website, called the Injury Tracking Application (ITA), for affected employers to electronically submit their data.
The first step to submitting records via the ITA is to create an account. After successfully creating a new account, affected employers must create an establishment and enter data for each establishment. The ITA will send a confirmation email after the process is completed. OSHA approximates that it will take a typical employer about 10 minutes to create an account and another 10 minutes to enter the required information from the Summary of Work-Related Injuries and Illness (Form OSHA 300A). To assist affected employers to become familiar with the submission process, OSHA has created a sandbox test ITA site where employers can create a test account and enter hypothetical data.
ADP clients can learn more about OSHA injury and illness recordkeeping and reporting in upcoming ADP University sessions on this topic. The dates and times of the ADP University sessions will be published as soon as they are available. For additional information, please contact your ADP HR Business Partner or Risk & Safety Consultant.