It’s been years in the making and has no shortage of critics, but OSHA’s new workplace injury and illness recordkeeping rule finally goes into effect Dec. 15.
Under the rule, companies with 250 or more employees – as well as those with more than 20 employees in certain high-risk industries such as construction and manufacturing – are required to submit their completed 2016 300A data via OSHA’S Injury Tracking Application website by that date.
This form shouldn’t take a lot of time to tackle. It does not list specific injuries, employee names or incident details. Instead, it merely summarizes the number of injuries, total numbers of days away and days transferred/restricted, and total number of injuries and illnesses by broad category. More detailed forms will need to be filed next year.
It’s important to note that the rule doesn’t require companies to maintain new records; it just mandates electronic filing of records employers should have been keeping already.
OSHA’s website offers you three options for submitting your data.
One option allows you to manually enter data into an online form.
Another option gives you the ability to upload a CSV file (like an Excel spreadsheet) to process a single or multiple establishments at the same time.
For the third option, if you use an automated recordkeeping system, you can submit your data electronically using an application programming interface—or API.
While OSHA says it’s tried to make things easy, critics say the rule imposes a new administrative burden on employers. There also are worries about false conclusions that may be drawn from incomplete information and the room for error in manually copying data into the new system.
Nonetheless, OSHA says analysis of the data it now collects electronically will improve its “ability to identify, target, and remove safety and health hazards, thereby preventing workplace injuries, illnesses, and deaths.”
In explaining its rationale for the rule, OSHA said it believes making injury information publicly available will “nudge” employers to focus on safety. “And, as we have seen in many examples, more attention to safety will save the lives and limbs of many workers, and will ultimately help the employer’s bottom line as well,” it said.
Some employers have interpreted this to be an effort to “shame” companies based on their injury and illness records.
The rule also requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation.
The deadline for 2017 data is July 1, 2018. Data for 2018 will be due March 2, 2019. The annual deadline thereafter for submitting the prior calendar year’s data will be March 2.
Lastly, it should be noted that OSHA is reviewing certain provisions of the rule and is expected to share its thoughts in an official notice sometime next year.
John Mayerle is CCIG’s Director of Risk Control. He can be reached at email@example.com or 720-330-7919.
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