OSHA Extends Deadline to 12/15/17 for Electronic Reporting via ITA

For the second time this year, OSHA has extended the deadline for electronic reporting of occupational injury and illness summary information, as required by its “Improve Tracking of Workplace Injuries and Illnesses” (aka Electronic Reporting) rule. The new deadline, as announced on OSHA’s page for its Injury Tracking Application (ITA), is December 15, 2015.

The new deadline represents a two-week extension from the most recent former deadline of December 1, 2015. That earlier deadline had itself been an extension from the original reporting deadline of July 1, 2017.

Let’s review the basic information regarding who must submit electronic records to OSHA by December 15, what information they will need to submit, and the submission process itself.

Who Must Submit Recordkeeping Data to OSHA’s ITA by December 15, 2017?

Establishments with 250 or more employees that are currently required to keep injury and illness records under the OSHA Recordkeeping Standard, as well as establishments with 20-249 employees that are also covered by the OSHA Recordkeeping Standard and operating in certain industries with historically high rates of occupational injuries and illnesses will be required to submit that data electronically.

These covered establishments must submit required data from their reporting year 2016 OSHA 300A forms (Summary of Work-Related Injuries and Illnesses) to OSHA via the ITA by December 15, 2017. These same establishments are still also required to post the signed hard copies of form 300A in their facilities annually between February and April.

Please remember the distinction that applicability of the Recordkeeping Rule is determined by company size, but the additional applicability of the electronic reporting obligation is determined by establishment size.

What Are the Next Deadlines?

Next year, covered establishments with 250 or more employees must submit information from their 300A forms as well as their 300 forms (Log of Work-Related Injuries and Illnesses) and 301 form (Injury and Illness Incident Report) through the ITA by July 1, 2018. Covered establishments with between 20 and 249 employees will still only need to submit the 300A information by that date.

Beginning in 2019, and every year thereafter, covered establishments will need to submit the same information required in 2018 by March 2. The table below summarizes reporting obligations and established deadlines, and is current as of this writing.

Since OSHA has already extended the initial deadline twice, it is possible that OSHA will eventually revise some of the deadlines below. Please continue to check the ITA page for updates.

 

Submission Year

Establishments with 250 or more employees

Establishments with 20-249 employees Submission deadline
2017

Form 300A

Form 300A

Dec 15, 2017

2018

Forms 300A, 300, 301

Form 300A

July 1, 2018

2019 Forms 300A, 300, 301 Form 300A

March 2, 2019

 

How do I submit data to the ITA?

Let’s review the submission process. The secure website currently offers three options for data submission:

  1. Manual Data Entry: This first (and potentially most time consuming) option enables users to manually enter data into web form fields that mirror the paper form 300A.
  2. CSV File Upload: The second option lets users upload a CSV file to quickly submit data for single or multiple establishments at the same time. The ITA website currently offers full instructionsfor this upload method, along with a CSV file template and sample file.
  3. API Plugin: The third option allows users of recordkeeping software systems to transmit data electronically via an application programming interface (API). This method requires the use of a unique API token generated by the ITA website, and integration with your recordkeeping system that may necessitate involvement of IT staff and your software provider.

OSHA estimates that it will take a typical establishment with 20-249 employees that is required to report about 10 minutes to create an account, and another 10 minutes to enter the required information from form 300A. For typical establishments with 250 or more employees, the agency estimates that it will take the same amount of time to enter the required information from form 300A, and an additional 12 minutes to enter the required information for each injury or illness recorded on the 300 and 301 forms.

Let VelocityEHS Help!

Do you need more guidance on the applicability of the electronic reporting rule, the reporting deadlines, and the submission process? Check out our ITA Cheat Sheet, or our on-demand webinar on the ITA for the information you need.

EHS management software with the ability to export data in a standard CSV file format that meets OSHA’s specifications can significantly streamline the electronic submission process. The VelocityEHS Incident Management solution makes it easy for employers and employees to more accurately record workplace incidents, near-misses and hazards of all types, and automatically generate your OSHA forms 300, 300A, and 301. Our solution even allows users to generate properly formatted injury and illness summary reports for instant electronic submission to the ITA. With VelocityEHS, you can take the anxiety out of compliance with OSHA’s electronic reporting rule and have the tools you need to improve your incident management performance.