A month after announcing its intention to propose extending the deadline to electronically submit 2016 300A data, OSHA has officially announced the new submission deadline.
In May of 2016, the final rule “Improve Tracking of Workplace Injuries and Illnesses” was issued by the Occupational Safety and Health Administration (OSHA) to revise its recording and reporting requirements, and became effective on January 1, 2017.
According to the final rule, establishments with at least 250 workers must electronically submit data from OSHA forms 300, 300A and 301 annually. The reporting requirements of the final rule will be phased in over two years, with the original deadline being July 1, 2017, at which time all establishments impacted by the ruling were expected to electronically submit their annual 2016 Form 300A data to OSHA.
With this published rule-making change, the first submission deadline will instead be extended to December 15, 2017.
What will be the effect of this new deadline?
When the final rule was first published, OSHA revealed its intention to provide a secure Injury Tracking Application (ITA) web site for the electronic submission of recordkeeping information. In addition, to enable users of current OSHA recordkeeping software systems to submit their incident data electronically, OSHA had planned to offer a CSV file upload tool and an Application Programming Interface (API). Both the secure ITA web site and API were scheduled to launch in February of 2017, and have currently been given the new availability date of August 1.
UPDATE: On August 1, 2017, OSHA made its ITA web site available to the public. Safety professionals are now able to submit their 300A data to comply with the final rule.
Delaying the ruling’s first submission deadline provides OSHA with more time to build and release the ITA site and other data submission tools, as well as give time for the new Sectary of Labor Alexander Acosta to fill the vacant seats in OSHA's staff, such as the Assistant Secretary and Chief of Staff. However, the postponement of the rule’s submission deadline could also potentially allow one of the federal court cases challenging the rule to determine the legality of the rule’s anti-retaliation provisions before employers are required to comply with electronic submission deadlines.
Regardless, with the launch of IndustrySafe’s 5.11 Update users of IndustrySafe are already able to prepare and test their data. This update allows organizations to generate a CSV file compatible with OSHA’s electronic submission requirements, thanks to technical specifications released by OSHA when the rule was first announced.