OSHA Issues Enforcement Guidance For Electronic Recordkeeping Rule And Promises Aggressive Enforcement

Cozen O'Connor
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Cozen O'Connor

As discussed in a previous blog, covered employers were required to electronically submit 300A data for the calendar year 2020 between January 2, 2021, through March 2, 2021. In a recent standard interpretation dated May 6, 2021, OSHA issued enforcement guidance stating employers who could not do so because of issues associated with the Injury Tracking Application (ITA) shall not be cited. Provided the data was submitted on a timely basis once the ITA became operational. Accordingly, employers are advised that they should keep written documentation if they experience any issues with using the ITA moving forward. 

In addition, OSHA announced that it is developing an analytic approach to identifying non-responders from the previous calendar year’s data collection to ensure “full compliance with this regulation.”

Employers should be prepared for much more aggressive OSHA enforcement in all areas, including recordkeeping.nThe White House recently proposed a $64 million boost to OSHA’s budget, including 362 new full-time equivalent staff positions to accomplish this objective. 

A copy of the standard interpretation can be found here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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