Deadline to Electronically Submit OSHA Data

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November 21, 2017
Matthew Horn
SmithAmundsen OSHA Legal Update

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BREAKING NEWS: In follow up to our alert from yesterday included below, OSHA issued a press release this morning extending the deadline to electronically report from December 1st to December 15th. All other information in the alert remains unchanged.
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On June 27, 2017, OSHA issued a press release announcing that it would be delaying the compliance date for its Rule requiring most employers to electronically submit their injury and illness data to OSHA. The press release pushed back the compliance date back four months, from July 1, 2017 to December 1, 2017, so OSHA could review the Rule closely. Just over two weeks later, OSHA issued another press release announcing that it would be 

launching its website allowing employers to submit their injury and illness data on August 1, 2017. On August 1, 2017, OSHA made good on that promise and launched its website, which is linked here. To date, despite OSHA’s promise to review the Rule closely, it has taken no action to roll back or delay the electronic reporting requirements, so the December 1st deadline remains.

Under the Rule, virtually all employers with twenty or more employees are required to submit their completed Form 300A for 2016 by December 1, 2017. In 2018, employers with twenty or more employees must submit their completed Form 300A for 2017 by July 1, 2018, and those employers with more than 250 employees must submit their Form 300 and 301s by that deadline, as well.

While we were hoping OSHA would roll back or delay the Rule, it appears that is not going to happen. Accordingly, all applicable employers would be well-served submitting their data online no later than December 1st.