Seyfarth Synopsis:  As most employers probably know by now, OSHA’s revised recordkeeping rule requires certain employers to electronically file injury and illness data with OSHA. Originally the reporting deadline was July 1, 2017. OSHA has again extended the deadline, this time to December 15, 2017.

During the previous extension period, it appeared that OSHA might be reconsidering the rule, with a possibility of modifications or a complete revocation of the rule by December 1, 2017. However with the recent extension to December 15, it appears that the rule will remain unchanged for the time being and that covered employers must report by the new deadline.

As a reminder, establishments with 250 or more employees must submit information electronically from their 2016 Form 300A by December 15, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) beginning in 2018.

Establishments with 20-249 employees operating in what OSHA deems to be “high-risk industries” (including department stores, nursing homes, construction) must submit information from their 2016 Form 300A by the December 15, 2017 deadline. These same employers will continue to only submit information from their 300A forms in later years.

Although OSHA’s electronic reporting webpage experienced malfunctions earlier this year, the webpage now appears to be working.