Written by; Darcy Cook, Safety Trainers
What are the changes is OSHA’s recordkeeping requirements for the manufacturing industry?
OSHA has adopted a new electronic data submission rule that took effect January 1, 2017. The new rule requires certain categories of employers (see applicability thresholds below) to electronically submit injury and illness data that they are already required to record on their on-site OSHA injury and illness forms. While the rule took effect on January 1, 2017, according to OSHA, the website employers must use went live in February 2017. Some of the data submitted will ultimately be posted to the OSHA website. The amount of data submitted will vary depending on the size of the company and the type of industry.
OSHA will provide a secure website that offers three options for data submission:
- Users will be able to manually enter data into a web form.
- Users will be able to upload a CSV file in order to process single or multiple establishments at the same time.
- Users of automated record-keeping systems will have the ability to transmit data electronically via an application programming interface (API).
The OSHA website link is available here: https://www.osha.gov/injuryreporting/index.html.
Compliance Thresholds and Schedule
The new reporting requirements will be phased in over two years:
- Effective July 1, 2017: Establishments with 250 or more employees in industries covered by the record-keeping regulation must submit information from their 2016 Form 300A and 2017 data on July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
- Effective July 1, 2017: Establishments with 20–249 employees in certain high-risk industries (OSHA defines these as industries with historically high rates of occupational injuries and illnesses) must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
The list of Industries covered by this rule can be found on OSHA website. If you believe you would be exempt under the small employer rule, you should verify by visiting OSHA’s website and looking for your NAICS code on the list. The list of high-risk industries is available at the OSHA website. Finally, new industries have been added to the record keeping rule. Check to see if you are on the newly required list.
As a reminder, make sure that your OSHA 300A log is posted in an area where all of your employees can access it. Even if you had zero recordables on your OSHA 300 A log, you still must post with zeros. This document must be posted from February 1, 2019- April 30, 2019. This document must be signed by a company executive. 29 CFR 1904.32(b)(3) states How do I certify the annual summary? A company executive must certify that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete.