OSHA Proposes to Amend Electronic Recordkeeping Requirement

OSHA has proposed to amend its recordkeeping regulation which could limit how much injury and illness information employers must submit electronically. Pursuant to the recent Spring 2018 Regulatory Agenda, OSHA indicated that the amendment would “remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees which are required to routinely keep injury and illness records. Under the proposed rule, these establishments would be required to electronically submit only information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).”

In addition, OSHA seeks comments on the “the costs and benefits of adding the Employer Identification Number (EIN) to the data collection to increase the likelihood that the Bureau of Labor Statistics (BLS) would be able to match OSHA-collected data to BLS Survey of Occupational Injury and Illness (SOII) data and potentially reduce the burden on employers who are required to report injury and illness data” to both OSHA and BLS.

On May 23, 2018, OSHA sent this proposal to the Office of Management and Budget for review. OSHA hopes to issue a Notice of Proposed Rulemaking as early as July 2018.