OSHA's New Final Rule Regarding The Electronic Submission Of Data

OSHA recently passed a new rule affecting  employers who are currently required to  maintain injury and illness information. If your  organization falls into this category, it will also  have to submit the information electronically to  OSHA. This new rule, an amendment to the  recordkeeping regulations detailed in 29 CFR part 1904,

will affect your company differently based on its number of employees:

  • Establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A and 301.
  • Establishments with 20-240 employees in certain high hazard industries must electronically submit information from OSHA form 300A only.

You may be wondering, will we need to report additional injury or illness information to OSHA, or will the information need to be modified?

The answer is no. The rule only changes how employers are to submit the information. The rule also does not add to or change the recording criteria or definitions for these records. If you already use a robust safety platform to comply with OSHA standards, the transition will be manageable. However, EHS professionals who still fill out OSHA forms the old-fashioned way have some catching up to do.

Another caveat to this new rule – OSHA intends to publicly disclose the company-specific injury and illness data it collects at www.osha.gov (while omitting information that would single out employees). The release of this data will leave companies’ safety records vulnerable to scrutiny from potential employees, customers and the general public. Before anyone decides to accept a job offer or give you their business, they will be able to check your company’s safety records. Using the power of public opinion, OSHA has upped the consequences of a poor safety record.

Companies should look at this rule as an opportunity rather than a threat. This rule is a catalyst to changing your organization’s safety culture and properly implementing a modern health & safety system. If you haven’t done so already, it’s time to embrace electronic record keeping, which will allow employees to immediately access injury and incident information saving valuable man hours. With performance data, organizations can track their progress in real time, make decisions and execute those decisions company-wide. As a result, incidents will decrease, employees will be safer and companies will improve their bottom line.

Additionally, this new rule will provide OSHA with substantially more data. OSHA will use statistics to identify industry trends and make prompt data-backed decisions aimed at further protecting workers.

The new requirement takes effect August 10th, with phased-in data submissions beginning in 2017.

Given the reputational risks with this new requirement, how do you think employers will respond?

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