Employers now will be able to electronic submit their Form 300A data beginning Aug. 1 thanks to OSHA's web-based Injury Tracking Application (ITA).
OSHA recently extended the deadline for providing 2016 Form 300A data to Dec. 1 in an effort to allow employers to become familiar with the new web-based reporting platform as well as provide time for the Trump administration to review the requirements before enacting them.
The agency's data submission process has four steps including:
- Creating an establishment
- Adding 300A summary data
- Submitting data to OSHA
- Reviewing the confirmation email
There are three options for data submission, according to OSHA. The first enables users to manually enter data. The second allows employers to upload a CSV file to process single or multiple establishments at the same time. Lastly, an application programming interface will allow users to sync automated record keeping systems directly to the platform.
The form will be accessible from the ITA webpage. The ITA webpage also includes information on reporting requirements, a list of frequently asked questions and a link to request assistance with completing the form.
OSHA Delayed Recordkeeping Rule
On May 17, OSHA announced it was indefinitely delaying implementation of the recordkeeping rule that originally was scheduled to take effect July 1. Federal lawsuits have been filed regarding the rule.
While the recordkeeping rule does not create new obligations for reporting, OSHA was prepared to electronically post injury and illness data on its website from all workplaces with 20 or more employees and for those in certain high-risk industries. This would make the information publicly available, and submission was to be phased-in based on employer establishment size and industry.
Former Assistant Secretary of Labor (OSHA) Edwin G. Foulke Jr. is a partner in the Atlanta and Washington, D.C. offices of Fisher Phillips. He co-chairs the firm's Workplace Safety and Catastrophe Management Practice Group.
Foulke said he hears a new secretary of labor for OSHA will be nominated (and likely confirmed) in September, and the deadline for providing the 300A form isn't until Dec. 1. Foulke said he is suggesting to clients to wait a few months until the new OSHA administrator is in office and challenges to the publication of injury and illness data to OSHA's website have been settled before posting their injury and illness data.
"If the electronic posting component is dropped, what will OSHA do with that data?" Foulke wondered. "I'm telling clients to wait and see how things shake out."