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Changes to OSHA Record keeping Rules: Steps to Ensure Compliance

Julie Copeland

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Under a final rule that becomes effective January 1, 2017, OSHA will revise its requirements for recording and submitting records of workplace injuries and illnesses. This new rule will require some of this recorded information to be submitted to OSHA electronically for posting to the OSHA website.


What is Changing?

Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from OSHA forms 300, 300A and 301. Companies with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses must submit data from OSHA form 300A. The industries deemed highly hazardous include construction, manufacturing, retail, utilities and transportation among others.

All establishments required to submit electronic records must submit their annual Form 300A to OSHA by July 1,2017 and on July 1, 2018 companies with 250 or more employees must submit forms 300, 300A and 301. Beginning in 2019, the submission deadline will change from July 1 to March 2.

Why is OSHA Changing the Rule?

OSHA is establishing this new rule with the idea that it will help keep workers safer and make employers, the public and the government better informed about workplace hazards. According to OSHA releasing the data in standard open formats will encourage employers to increase their efforts to prevent worker injuries and illnesses. In addition, the change will enable researchers to examine the data in innovative ways that may help employers make their workplaces safer and identify new hazards before they become an issue.

OSHA is applying behavioral science to this rule with the notion that public disclosure of data will “nudge” employers to reduce work-related injuries and illnesses in order to demonstrate to investors, job seekers, customers, and the broader public that their workplaces are safe and healthy environments for their employees. Employers today cannot compare injury experience with other businesses in their industry, just the industry as a whole. Access to company specific data will provide a true benchmark for organizations and establish true safety leaders within each industry.

What Other Changes Must Employers Be Aware Of?

In addition to the changes mentioned above, OSHA has also outlined a few provisions to promote complete and accurate reporting of work-related injuries and illnesses. These provisions ensure that employees feel free to report injuries and illnesses without fear of retaliation.

  • Employers must inform employees of their right to report work-related injuries and illnesses free from retaliation
  • An employer’s procedure for reporting work-related injuries and illnesses must be reasonable and must not deter or discourage employees from reporting
  • An employer may not retaliate against employees for reporting work-related injuries or illnesses

What Steps Should Employers Take to Ensure Compliance?

It is now more important than ever for employers to understand and assess the risk for injuries and hazards in their workplace. A good starting point is to conduct a workplace safety site audit of your facility. Our team of EH&S professionals will conduct a systematic, documented and objective analysis of your site and operations to develop an improvement plan for your business. The team will also review your written programs, employee training records, inspection forms and injury logs to identify any regulatory or safety gaps that put your workers at risk.

Arbill also offers both in-person and online training courses that can help you maintain OSHA compliance and help your workers understand the best ways to protect their health and safety.

For those organizations who have recently had an OSHA inspection or received a notice of enforcement we also offer consultants who can advocate on your behalf to the agencies involved. Our consultants will work to reduce your fines and workers’ compensation premiums.

Schedule a consultation with an Arbill Safety Expert today to identify areas of improvement and develop a customized blueprint of the safety equipment, training and services you need to maintain compliance and build a culture of safety.

Have a Safe Day!

Topics: osha violations, OSHA citations, OSHA, safety costs, Safety logs

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