OSHA Recordkeeping: OSHA Only Requiring Electronic Submission Of 300A Forms

Jackson Lewis P.C.
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In its latest Regulatory Agenda, the Occupational Safety and Health Administration (OSHA) indicated that it was undergoing rulemaking to revise the “Improve Tracking of Workplace Injuries and Illnesses” regulation promulgated under the Obama Administration. OSHA noted it was considering deleting the requirement for employers with 250 or more employees at an establishment to electronically submit its 300 Log, 301 Forms, along with the 300A Form.

Recently, OSHA made clear that it will not collect or require employers with 250 or more employees per establishment to submit the 300 Log or the 301 Forms. OSHA will require all employers covered by the regulation to submit only the 2017 300A Form by July 1, 2018. Beginning in 2019, and every year thereafter, the 300A Forms must be submitted by March 2.

According to OSHA, “OSHA is not accepting Form 300 and 301 information at this time.” The agency announced 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.

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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