OSHA’s Electronic Recordkeeping Regulation


After many delays, OSHA finally set the date of December 31, 2017 for certain companies to submit injury/illness data electronically through the agency’s Injury Tracking Application (ITA).  According to OSHA, Establishments that meet any of the following criteria DO NOT have to send their information to us. Remember, these criteria apply at the establishment level, not to the firm as a whole.  Please check the following links to determine if your business must comply.

  • The establishment’s peak employment during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
  • The establishment’s industry is on this list, regardless of the size of the establishment.
  • The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on this list.

If your business has an establishment that is covered under the North American Industrial Classification System (NAICS) categories of Agriculture (11), Construction (23) or Manufacturing (31-33) and the establishment has more than 19 employees during any part of the year, you are required to comply.

At the end of April, OSHA corrected an error which exempted several state plans from this requirement.  The agency sent out a release late last month indicating that covered firms in state plan states must also comply.  There is no requirement to retroactively file the 2016 data into the OSHA portal.

If your company has multiple branch operations, each establishment is to be considered separately.  Therefore, even if your company has 200 employees, if each branch has 19 or less, there is no need to submit your OSHA 300 A injury/illness information electronically.

If you did not submit the information from your 2016 300 A forms by the deadline, OSHA is no longer accepting that information.  You need to submit your 2017 information to OSHA by July 1, 2018 this year.  That date changes to March 1 in 2019 and in subsequent years.

It is expected that there will be some changes to the program which may impact reporting for this year.  With that in mind, you may choose to hold off until closer to the July 1 date to submit your 2017 information.  On the other hand, if you did not submit the information at the end of 2017, you may want to submit your 2017 information now to show “good faith” to OSHA during an inspection.

Please contact us if you have any questions regarding this requirement.  We can let you know if you are covered by this regulation and  guide you through the reporting process.

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