By:  Evan Sauer
       evan@rdlawyers.com
       877-809-4567 x3

On May 12, 2016, the Occupational Safety & Health Administration (“OSHA”) published a final rule amending 29 CFR 1904.41 establishing three new electronic reporting requirements for certain businesses. The rule becomes effective January 1, 2017.

Who does the Rule Apply to?

Under the new rule, certain businesses will be required to electronically submit to OSHA information from their injury and illness logs on an annual basis. The rule applies to: (a) those businesses that are subject to reporting regulations under OSHA and have employed 250 or more employees at any time during the previous calendar year; and (b) those businesses, in certain industries (high rates of occupational injuries and illnesses), that have employed 20-249 employees at any time during the previous calendar year.

What Information must be Submitted?

For the year 2017, electronic data submission from OSHA Form 300A – Summary of Work-Related Injuries and Illnesses must be made by July 1, 2017 for businesses with 250 or more employees and businesses with 20-249 employees (in certain industries).  For the year 2018, electronic data submission from OSHA Forms 300 – Log of Work-Related Injuries and Illnesses, 300A – Summary of Work-Related Injuries and Illnesses, and 301 – Injury and Illness Incident Report must be made by July 1, 2018 for businesses with 250 ore more employees. Businesses with 20-249 employees (in certain industries) will need to submit Form 300A only. The electronic submissions will be made public by OSHA.

Please contact us for more information about this change and OSHA.  

Evan Sauer is a Chicago business attorney at Reda & Des Jardins, LLC a forward-thinking, technologically savvy law firm providing top-notch legal services to clients ranging from startups to large companies in a variety of industries.