The Public Employee Safety and Health Bureau (PESH), enforces safety and health standards promulgated under the United States Occupational Safety and Health Act (OSHA) and several state standards and gives occupational safety and health protection to all public sector employees, including state, county, town, village governments, public authorities, school districts, paid and volunteer fire departments.
In May 2024, PESH proposed regulations to amend its illness and injury recordkeeping and reporting requirements to align with the changes to OSHA’s recordkeeping regulations as the state’s standards must conform with federal OSHA standards. Effective July 31, 2024, via the July 31 State Register the proposed changes were adopted without further edits.
To be consistent with OSHA requirements, three categories of covered employers must electronically submit information to PESH by March 2 each year as specified by the Commissioner of Labor and identified on the Department of Labor’s website as follows:
- Category 1: Employers with an establishment that had 20–249 employees at any time during the previous calendar year and are classified in a designated industry under the regulations must submit the required information from the Summary of Work-Related Injuries and Illnesses Form SH-900.1.
- Category 2: Employers with an establishment with 250 or more employees at any time during the previous calendar year are required by this part to keep records; establishments in this category must submit the necessary information from the Summary of Work-Related Injuries and Illnesses Form SH-900.1.
- Category 3: Employers with an establishment that had 100 or more employees at any time during the previous calendar year and are classified in an industry listed in Section 801.41 (e) of the regulations; establishments in this category must also submit the required information from the Log of Work-Related Injuries and Illnesses Form SH900 and Injury and Illness Incident Report Form SH-900.2, in addition to the necessary information from the Summary of Work-Related Injuries and Illnesses Form SH-900.1.
Next Steps
Employers should review the proposed regulations to determine if they are subject to any of the reporting requirements and ensure that if applicable, electronic submissions of any applicable forms (Forms SH900, SH-900.2, and/or SH-900.1) are submitted by March 2 each year.
