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OSHA’s deadline for submitting 2018 Form 300A data via the Injury Tracking Application (ITA) is March 2, 2019. That’s significantly earlier in the year than the submission deadline has been for the past two reporting years since OSHA’s Improve Tracking of Workplace Injuries and Illnesses final rule went into effect. Is your business ready?

Now is an excellent time to review the background and applicability of the rule, and take a deeper look at how these reporting requirements may affect your business.

The Background

Prior to the Improve Tracking of Workplace Injuries and Illnesses final rule, OSHA collected injury and illness data from employers through the OSHA Data Initiative (ODI) survey. The ODI was a paper survey that required a great deal of time and effort on the part of both employers and OSHA to complete and process. In May 2016, OSHA issued the final rule revising the Recordkeeping Standard to require some establishments already subject to the recordkeeping requirements to electronically transmit injury and illness data directly to OSHA.

The 2016 revision required establishments with 250 or more employees, as well as establishments in certain high risk industries with between 20 and 249 employees, to electronically transmit data from their Form 300A summaries to OSHA. The deadline for submission of calendar year 2016 data was December 31, 2017, after being postponed several times from its original due date of July 1, 2017.

At the time, the 2016 final rule also required affected establishments with 250 or more employees to submit electronic data from 2017 calendar year 300 and 301 forms to OSHA by July 1, 2018, while only requiring the smaller size establishments to submit 300A data. However, as that deadline approached in May 2018, OSHA published a note on their ITA website indicating that they would only be collecting 300A data from all establishments subject to the rule.

OSHA followed that up with a Notice of Proposed Rulemaking (NPRM) in July 2018 and final rule in late January 2019 revising the Recordkeeping Standard. The revisions officially removed the requirements for some establishments to submit 300 and 301 data established by the 2016 final rule. All affected establishments must now only submit electronic 300A data to OSHA by the annual deadline.

Current applicability and deadlines are summarized in the table below:

What’s Different This Year?

As the table above shows, the deadline for submission of calendar year 2018 Form 300A data is March 2, and will remain March 2 each year going forward. That’s nearly four months earlier than the July 1 deadline last year for CY 2017 data, and nearly 10 months earlier than the December 31, 2017 deadline for CY 2016 data.

Basically, every reporting year beginning this year, affected establishments will need to electronically transmit their 300A data to OSHA just about a month after completing, signing and posting the physical 300A form in their facilities.

Why Does It Matter?

Well, let’s take a step back for a moment and ask why OSHA required employers to maintain injury and illness records in the first place.

OSHA was born out of the Occupational Safety and Health Act of 1970, and soon after issued the Recordkeeping Standard in 1971. As one of OSHA first standards, you can imagine how important the recordkeeping requirements were to accomplishing the agency’s overall mandate.

OSHA knew that without these records, employers would lack crucial information about safety performance needed to prevent future injuries and illnesses from occurring. Employees would lack the awareness of workplace injuries and illnesses they needed to work safely, and OSHA themselves would have no way of obtaining the information they needed to fulfill their mandate of protecting the U.S. workforce.

Initial Results & Future Actions

OSHA stated that it expected to receive about 350,000 ITA submissions for the initial December 31, 2017 deadline. However, results revealed that only about 153,000 reports were submitted. This suggests that many establishments that should have reported failed to do so, likely due a lack of awareness of their requirements under the new final rule or confusion regarding its applicability. During speaking engagements at conferences last year, I have met quite a few people who had only recently learned that they should have reported, months after the deadline had already passed.

Unfortunately, there’s some pretty bad news for those folks. OSHA has recently announced the return of its site-specific targeting inspection program (SST) for non-construction workplaces with 20 or more employees. Prior OSHA SST programs had used injury and illness data gathered through the old ODI survey to prioritize potential inspection targets. The new program is the first to rely on ITA data, specifically 2016 calendar year data that was due by December 31, 2017, in order to prioritize inspection and enforcement activities. It just so happens that one of the main criteria OSHA is using to decide who to inspect is whether the establishment failed to submit their 2016 Form 300A data.

Additionally, OSHA will be using ITA data to identify establishments with a Days Away, Restricted or Transferred (DART) rate that is higher than their industry average. Since DART is widely accepted as a reliable indicator for the occurrence of more serious recordable injuries and illnesses, OSHA sees good reason to prioritize inspections of those establishments with elevated rates relative to their peers. Additionally, OSHA has indicated it will be doing random inspections of establishments who reported significantly lower DART rates, to “verify the reliability of the Form 300A data,” in the agency’s words.

Lessons Learned

There are several important takeaways from this. One is that it’s important to complete and post your physical 300A form in your workplace, and ensure that the information on it factually correct. Another is to be very sure whether electronic reporting requirements apply to your establishment, and to submit your data by March 2 if you determine you are subject to the rule. If you were also subject to these requirements in 2016 and 2017 and did not submit, consider being proactive and submitting that information via the ITA as quickly as possible.

Finally, be familiar with your 300A data and the bigger picture of what it means to your establishment. Know what your DART rate is, and how it compares to the industry average for your sector, as rates that are either significantly higher or lower than your industry average will increase your chance of being inspected.

This is also a good time to take stock of your larger incident management and recordkeeping programs. Make sure that your incident management system makes it easy to capture incidents as soon as they happen, which is the first step to ensuring accurate records. Look for ways to streamline and centralize your incident records, which will improve your management efficiency and provide for faster access in the event of an OSHA inspection. Finally, consider systems that will help you quickly and accurately generate electronic files containing your 300A data for submission to OSHA via the ITA.

With better tools and better planning, you’ll be prepared for the March 2 deadline, and ready should an OSHA inspector arrive at your door.

Let VelocityEHS Help!

The VelocityEHS Incident Management solution and VelocityEHS Mobile App give you and your workforce the ability to record workplace incidents from anywhere at any time, improving the timeliness and accuracy of your injury and illness records.  You’ll have the additional advantage of having all of your injury and illness data and records in one centralized, accessible location, which is a huge benefit if you have responsibility for more than one establishment subject to the Recordkeeping Standard.

VelocityEHS also makes meeting your electronic reporting requirements fast and simple. Our Incident Management solution allow you to automatically generate and export fully-formatted 300A injury and illness summary data in a standard .CSV file format for direct electronic submission to OSHA’s online Injury Tracking Application (ITA).

To see for yourself how fast and simple VelocityEHS can make OSHA recordkeeping and electronic reporting compliance, Request a Demo today!