Although the ultimate fate of certain provisions in OSHA’s electronic reporting regulation has not yet been decided, there is just over a week remaining before the December 1 deadline for certain employers to file their 2016 form 300A with OSHA, using the electronic portal found at its website.

The OSHA website provides a detailed description of covered employers, compliance dates and electronic portal instructions. But, here are the general guidelines:

Establishments with 250 or more employees in industries covered by OSHA’s recordkeeping regulation must electronically submit information from their 2016 Form 300A by December 1, 2017. These same employers will be required to electronically submit information from all 2017 forms (300A, 300 and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be electronically submitted by March 2 of each year.

Establishments with 20-249 employees in certain high-risk industries must electronically submit information from their 2016 Form 300A by December 1, 2017 and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be electronically submitted by March 2 of each year. The list of such “high-risk” industries, categorized by NAICS number can be found at OSHA’s website.

The new regulation does not change the manner in which employers are to collect/record occupational injury and illness information. It does require, however, electronic submission of the forms noted above, by the currently effective compliance deadlines.

If we learn of any changes or further postponements to the deadlines, we will issue a further Alert.