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Important Changes to OSHA’s Illness and Injury Reporting for Employers

The Occupational Safety and Health Administration (OSHA), the federal agency tasked with overseeing workplace safety, has enacted changes that will take effect on August 10, 2016. Prior to these changes, many employers had little to no interaction with OSHA. However, these new requirements will affect all employers, regardless of size and industry.

OSHA’s final rule will require employers to:

  • Establish and inform employees of a “reasonable” procedure to report work-related injuries and illnesses. The procedure must not discourage employees from accurately reporting a workplace injury or illness;
  • Inform employees of their right to report work-related injuries and illnesses free from retaliation. This requirement may be met by posting the “OSHA Job Safety and Health — It’s The Law” poster (dated April 2015 or later).
  • Prohibit discrimination against employees for reporting a work-related injuries, filing complaints regarding safety, or requesting to see the injury and illness logs.

In addition employers with 250 or more employees and/or employers with 20-249 employees in “high hazard” industries are subject to additional reporting requirements. Employers that fall into either of these categories will be required to submit injury and illness information electronically to OSHA on a periodic basis and; OSHA will post this information online. The new posting requirements are as follows:
– Businesses with 250 or more employees must submit the annual summary form 300A electronically by July 1, 2017; submit the Forms 300, 301, and 300A electronically by July 1, 2018; and then submit Forms 300, 301, and 300A annually beginning March 2, 2019.
– Businesses with 20-249 employees in “high-hazard” industries must submit Form 300A by July 1, 2017 and July 1, 2018, and then continue submission of Form 300A annually beginning March 2, 2019.

Employers can verify whether or not they are subject to these posting requirements by checking their NAICS code here. If employers are unsure of their NAICS code, it can be looked up here.

Clients can call the Helpline for additional information and/or questions regarding these changes at 585-381-8340 option 1.
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