This comprehensive guidebook will provide all the information employers need to know about OSHA’s electronic reporting requirement.
Introduction
Each year, millions of workers get hurt on the job. In order to help prevent work-related injuries and illnesses, OSHA has for decades required employers to keep track of these incidents by recording them in what is often called an “OSHA log.”
On May 12, 2016, Federal OSHA passed new regulations requiring employers to electronically submit injury data directly to OSHA for its review, in addition to keeping the OSHA 300, 300A, and 301 forms at the workplace.
This guidebook will teach you how to achieve compliance and avoid penalties from federal and state regulations.
Who Must Comply with Electronic Reporting?
Electronic reporting requirements are based on the size of an establishment. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. An employer may be comprised of one or more establishments.
To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment’s peak employment during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal and temporary workers. Compliance requirements are broken down into two categories:
250+ EMPLOYEES: All establishments with 250 or more employees covered by recordkeeping regulation must electronically submit to OSHA.
20 TO 249 EMPLOYEES: All establishments with 20-249 employees in “high risk” industries, based on their North American Insurance Classification System (NAICS) code. There are over 600 NAICS codes that apply, representing 65% of all NAICS codes. A majority of covered industries all under these top NAICS codes:
AGRICULTURE
64 NAICS codes
UTILITIES
14 NAICS codes
CONSTRUCTION
31 NAICS codes
MANUFACTURING
346 NAICS codes
WHOLESALE
71 NAICS codes
GENERAL/OTHER
145 NAICS codes
What Data Must I Submit By March 2nd?
The following information must included in electronic reporting for each required establishment. Data should reflect that establishment’s completed 2019 OSHA 300A Form.
ESTABLISHMENT INFORMATION
- Company name
- Establishment name
- Establishment full address
- Size of establishment
- Establishment type employer EIN
- NAICS code & industry description
- OSHA form 300A year
- Average annual employees
- Total hours worked
INJURY STATISTICS
- Total # of Cases with days away from work
- Total # of cases with job transfer or restriction
- Total # of other recordable cases
- Total # of days away from work
- Total # of days job transfer or restriction
- Total # of death cases
- Total # of injuries
- Total # of skin disorders
- Total # of respiratory conditions
- Total # of poisonings
- Total # of other illnesses
What if Employers Don’t Electronically Submit?
OSHA issued a directive in 2018 letting employers know exactly how they are going to use submitted electronic illness and injury records. Called Site Specific Targeting Inspections, or SST for short, this will be Federal OSHA’s main method of scheduling programmed comprehensive (“wall-to-wall”) inspections. SST targets work places of 20 or more employees and requires state plans to have their own inspecting targeting systems.
OSHA is taking action. They targeted one Ohio manufacturer after failing to comply and uncovered more than two dozen safety violations, which resulted in $724,380 fines.
Checklist: What Should Employers Do Now?
Now that you’re caught up on the electronic recordkeeping requirements, here are your takeaway action items:
How Can OSHAlogs Help?
OSHAlogs.com is designed to make OSHA recordkeeping an absolute breeze. It takes the guesswork out of electronic submission compliance by helping you verify and submitting data to the federal government automatically. Simply click one button to confirm your data, and you are done.
Sign up for a FREE OSHAlogs account today!
