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OSHA Delays Electronic Recordkeeping Compliance Date

In May, 2016, OSHA issued a Final Rule which was entitled "Improve Tracking of Workplace Injuries and Illnesses."

In addition to the anti-retaliation provisions, the Rule included new electronic reporting requirements for certain employers. Under the Rule, establishments with 250 or more employees will have to submit the OSHA 300A, 300 log and 301 forms electronically and establishments with 20 to 249 employees in certain "hazardous" industries are to submit in electronic format the OSHA 300A summary.

The effective date of the Final Rule was January 1, 2017, but electronic reporting and recording keeping requirements were to be phased in over a two-year period beginning July 1, 2017 when affected establishments were to submit the Form 300A Summary electronically.

However, on May 17, OSHA announced that it intends to delay the July 1, 2017 date. Specifically, OSHA's website announcement provides as follows:

OSHA is not accepting electronic submissions at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit information from their completed 2016 Form 300A electronically. Updates will be posted to the OSHA website at https://www.osha.gov/recordkeeping/ when they are available.

Employers covered by the Final Rule should continue to monitor forthcoming announcements from OSHA concerning a new compliance date and Wimberly Lawson will continue to update as information is made available from OSHA.


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