Just about a year ago, we told you about the Occupational Safety and Health Administration’s plan to move employer Form 300A reporting from a paper process to a publicly accessible online database. After a year in limbo, the Injury Tracking Application (ITA) will become available on August 1, 2017 to accept employers’ completed 2016 OSHA Form 300A.
Last month, OSHA announced the delay of the July 1, 2017, mandatory web-based filing implementation date until December 1, 2017. This provides employers with a four month period to become familiar with the new procedure and permits both the agency and the Administration time to review the new system before it goes into effect. Except for the initial implementation date, the original mandatory schedule remains:
| Submission Year | Employers with 250+ Employees | Employers with 20-249 Employees – in 68 specific industries | Submission Deadline |
| 2017 | Form 300A | Form 300A | December 1, 2017 |
| 2018 | Forms 300A, 300, 301 | Form 300A | July 1, 2018 |
| 2019 and beyond | Forms 300A, 300, 301 | Form 300A | March 2, 2019 (and March 2 of subsequent years) |
The new process is made up of four steps:
- Creating your establishment
- Entering Form 300A (and Forms 300 and 301 for large employers) summary data
- Submitting data to OSHA
- Reviewing the confirming receipt email from OSHA
The website offers three options for data submission:
- Manually enter data into a web form
- Upload a CSV file to process single or multiple establishments at the same time
- Transmit automated recordkeeping systems data electronically via an application programming interface
Employers wishing to take advantage of the opportunity to familiarize themselves with the new procedure before mandatory web filing commences on December 1, 2017, can find the new form and additional information, including Questions & Answers, at the ITA web page.
The concerns we expressed a year ago remain. Current regulations require maintenance of the reports for five years. However, once those records have been added to an internet data base, employers should recognize those records as being “permanently available.” With that in mind, is responsibility for preparing the reports appropriately placed within your organization? Should reporting personnel be trained to adhere more strictly to the regulations in determining what to report? Should each report be reviewed to ensure complete accuracy and delete conclusory statements, such as the “cause” of the injury or incident?
Since the new reporting regulations mean that all data reported to OSHA via the web will now be permanently available to anyone who wishes to check it out, it is more important than ever for employers to take precautions to mitigate the risks of inaccuracies and noncompliance.
If you have questions as to how these new requirements might impact your workforce, please call Kathy Mills or Jake Sitman at (610) 797-9000.
