Cal/OSHA 300A Electronic Reporting Deadline July 1, 2018!

Effective January 1, 2017, employers in states regulated by Federal OSHA were required to electronically submit Log 300 records of injuries and illnesses.

On April 30, 2018, Federal OSHA posted a “trade release” requiring all affected employers to submit injury and illness data in the Federal OSHA Injury Tracking Application (ITA) online portal, even if the employer is covered by a state plan that has not completed adoption of their own state rule.

Therefore, even though California has not yet adopted its own state rule, Cal/OSHA [link] is now advising employers to comply with Federal OSHA’s directive to provide Form 300A data covering the calendar year 2017. Federal OSHA is requiring affected employers to submit their data by July 1, 2018.

Who: Establishments (any one location) with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments (any one location) with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. Not all establishments are covered by this requirement. To review which establishments need to provide their 2017 data, see Federal OSHA’s ITA website.

What: Covered establishments must electronically submit information from their 2017 OSHA Form 300A Summary only.

Note: Covered establishments with 250 or more employees are now only required to provide their 2017 Form 300A summary data. OSHA is not accepting Form 300 and 301 information at this time. OSHA announced that it will issue a notice of proposed rulemaking (NPRM) to reconsider, revise, or remove provisions of the “Improve Tracking of Workplace Injuries and Illnesses” final rule, including the collection of the Forms 300/301 data.

When: In 2018, covered establishments must submit information from their completed 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.

How: OSHA will provide a secure website that offers three options for data submission. For specific instructions, go to Federal OSHA’s ITA website.