On April 30, 2018, federal OSHA posted a "trade release" requiring all affected employers to submit injury and illness data in the federal OSHA Injury Tracking Application (ITA) online portal, even if the employer is covered by a state plan that has not completed adoption of their own state rule:
Here is the official Cal-OSHA statement:
Employers can now begin to electronically report their Calendar Year (CY) 2017 Form 300A data to OSHA.
Employers can now begin to electronically report their Calendar Year (CY) 2017 Form 300A data to OSHA. All covered establishments must submit the information by July 1, 2018. Employers can view their submitted CY 2016 Form 300A summary information, but they cannot edit or submit additional 2016 data on this website. Remember, not all establishments are covered by this requirement. To review which establishments need to provide their 2017 data, click here.
Covered establishments with 250 or more employees are only required to provide their 2017 Form 300A summary data. OSHA is not accepting Form 300 and 301 information at this time. OSHA announced that 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. The Agency is currently drafting that NPRM and will seek comment on those provisions.
The new reporting requirements will be phased in over two years:
The anti-retaliation provisions become effective August 10, 2016, but OSHA delayed their enforcement until Dec. 1, 2016.
Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information 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) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by December 15, 2017 and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.
Deadline moved to December 15th!
The date by which certain employers are required to submit to OSHA the information from their completed 2016 Form 300A has been extended to December 15, 2017.
Be sure to pay close attention to the "WHO" section on the OSHA ITA page we have been listing. If you are not sure about the State OSHA reporting requirements for ITA you need to get clarification from them. This may save you considerable time by not needing to report certain establishments this round.
We also encourage you to officially submit inquiries on the sites, even if you may be confident with your reporting decision. This helps OSHA understand i a documented way any issues. One in particular is that an email address can only be used once in registration. So if you have two or more required OSHA ITA accounts to be set up, different email addresses are needed.
See "Help Request Form" at the bottom.
In reviewing and testing the new FROL OSHA ITA reports we have seen many employers that are making common errors in FROL that create reports that OSHA will reject. So REALLY do check your work.
- Two locations (Establishments) with the same name. Rejected.
- No "Average number of Employees" value. Rejected.
- No "1" value in the Pay periods field. Rejected.
It is now within six weeks of the OSHA ITA deadline for electronic submitting. FirstReport Online can produce these reports for you to submit. Remember that you are responsible for the accuracy and completeness of the data and FROL will produce what you have entered. There are some areas where your OSHA records of the past have less than perfect but OSHA site inspectors may have accepted and clarified paper reports with you. Online electronic transmitted will not be as forgiving by their computers.
Therefore we highly recommend that you review the detail specifications from their website in advance of your steps to transmit data. We have provided the OSHA web link again below and also a PDF copy of their CSV documentation to help you along.
Important OSHA detailed instructions for data compliance below:
A new FROL release over the weekend. There were some general navigation and permission updates but primarily this release focused on the customer's new ability to complete reports for OSHA ITA data transmittal for 2016 and the BLS Survey reports for 2017 based on standard 2016 specifications. If you have not been directly contacted by the BLS to do this survey on selected locations you have no requirement to produced their reports.
Get your data ready for the new FROL ITA and BLS SOII reports. Here are two "Pre-Release" articles to help you get up to speed with the new reports before they hit the street very soon. There may be some minor changes but this should help you prepare. As always, contact us at our Support Tickets for clarifications.
Here is the latest posting that announces Electronic submission starting August 1, 2017.
FROL will now continue system interface roll-out with the new OSHA access. Watch the announcements when you login to FROL as progress is made. Be sure to understand which locations need to report and set them up correctly in FROL. Not all locations are required.
Here is the latest posting that moves the deadline to December 1, 2017.
"Updated OSHA is not accepting electronic submissions of injury and illness logs at this time, and has published a notice of proposed rulemaking to extend the date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically from July 1, 2017 to December 1, 2017. Updates will be posted to this webpage when they are available."
FROL Update to capture data for the new OSHA submittals
You can now enter the NAICS code and Location "Type" in FROL to prepare for this coming report. You first need to activate the form fields by "Checking" the OSHA ITA box in the "Employer Profile". Then you can update the additional fields in the "Edit 300A Employment Info" OSHA form in FROL. Here are the two screens you will see.
In the "Employer Profile"
In the "Edit 300A Employment Info" input form. Remember, this is 2016 data!
May, 18-2017 Update:
Electronic Submission of Injury and Illness Records to OSHA
Updated OSHA is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically. Updates will be posted to this webpage when they are available.
The OSHA Electronic data transmission is currently on "Hold" at OSHA. See this page. above "Who"
There are rumors of it not happening due to law suits and politics but nothing official. Therefore, we still are proceeding like it may happen.
There are a couple steps in this process that we are preparing to educate users about. Here are some notes in advance of this.
1. By regulation, each location must have two additional data points. They will need to be entered on the forms in FROL where you add the average number of employees and total hours worked for the 300A summary. These fields are the NAICS code for the location and the Type code - (1,2 or 3). The NAICS code must be entered in this form and will not be inherited from profiles. The type code is based on the "Maximum number of “workers” at the location" not Average number of Employees. As I recall, "1" is less than 20, "2" is less than 250, and "3" is more than 250. Ones don't have to report unless they are high risk NAICS.
2. Our application can then create the correct CSV data file for submitting to OSHA electronically.
3. Each "Employer" must create an authorized account on the OSHA site. This authorization accepts all the locations for that employer. We have asked OSHA for clarification on who can request and manage this authorization. With this OSHA account, theoretically either the customer, the management group or the service provider may submit data. This process is the same no matter which of the entities does it.
4. The API for direct transmitting from providers such as FROL would be a third step in automating this. We are still waiting on OSHA to provide the API test site to even attempt this technically, the only thing they have provided is the data dictionary, not the submitting methodology. So, if they proceed with this reporting requirement I doubt that "4." can happen in 6 weeks (7/1/17).
Our recommendation for you to get ahead of this in case it happens is to start collecting the NAICS codes and Types for each location. We can get you a current spreadsheet of all the locations if that helps.
We are planning to release the input form this weekend or next.
More to follow.