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The Federal Occupational Safety and Health Administration (OSHA) has passed a final rule effective Jan.1, 2017 regarding electronic OSHA 300 log reporting.  While the new electronic OSHA 300 log reporting requirements will be phased in during the next two years, there are three key points about the new rule that clients and businesses need to be made aware.

  1. Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information for certain forms by the following deadlines:
    • 2016 Form 300A by July 1, 2017.
    • 2017 forms (300A, 300, and 301) by July 1, 2018
    • Beginning in 2019 and beyond, the information must be submitted by
      March 2.
  2. Establishments with 20-249 employees in certain high-risk industries must submit certain forms by the following deadlines:
    • 2016 Form 300A by July 1, 2017
    • 2017 Form 300A by July 1, 2018.
    • Beginning in 2019 and beyond, the information must be submitted by
      March 2.
  3. States under the OSHA State Plan must adopt requirements that are substantially identical to the requirements in this final rule within six months after publication of this final rule.

Anti-Retaliation Protections

The rule also prohibits employers from discouraging workers from reporting an injury or illness.  Further, the rule:

  • Requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation
  • Clarifies the existing implicit requirement that an employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting
  • Incorporates the existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses.

These provisions become effective August 10, 2016, but OSHA has delayed their enforcement until Nov. 1, 2016 in order to provide outreach to the regulated community.

To learn more about how this final rule may affect your business, contact your Lockton Loss Control Consultant.