2017 OSHAlogs.comCompliance Guidebook:Electronic Submissionof Injury and Illness Recordsto OSHAOSHAlogs

OSHAlogsHIGHLIGHTS The Occupational Safety and Health Administration (OSHA) now requiresemployers to electronically submit injury and illness data directly to OSHA. Establishments with 20 or more employees from selected industries and allestablishments covered by the recordkeeping regulation with 250 or moreemployees must comply. OSHA 300A data must be submitted to OSHA by December 1st, 2017. Some data will be posted on OSHA’s website for public consumption. Employers must upload their data via a CSV file or manually enter data for eachof their covered establishments. Violations for materially false, fictitious, or fraudulent statements can bepunished by a fine or by imprisonment of not more than five years, or both. The electronic submission requirements do not change any employer’sobligation to complete and retain injury and illness records.

OSHAlogsOVERVIEWEach year, millions of workers get hurt on the job. In order to help prevent workrelated injuries and illnesses, OSHA has for decades required employers to keeptrack of these incidents by recording them in what is often called an “OSHA log.”Starting in 2017, OSHA is now requiring employers to also electronically submit thisinjury data directly to OSHA for its review and posting on its website. Employershave until December 1st, 2017 to comply.OSHA is taking information that employers arealready required to collect and using these datato help keep workers safer and make employers,the public, and the government better informedabout workplace hazards.OSHA expects this new rule will help improveworkplace safety through expanded access totimely, establishment-specific injury and illnessinformation for OSHA, employers, employees,employee representatives, potential employees,customers, potential customers, and public healthresearchers.seekers, customers, and the broader public thattheir workplaces provide safe and healthy workenvironments for their employees.Access to establishment-specific data will enableemployers to benchmark their safety and healthperformance against industry leaders,encouraging them to improve their safetyprograms.The rule will also provide OSHA with data toassist the agency in improving allocation ofcompliance assistance — help OSHA provide toemployers who want to improve their safetystandards — and enforcement resources,expanding the Agency’s ability to identify, targetand remove safety and health hazards, therebypreventing workplace injuries, illnesses anddeaths.In addition, behavioral science suggests thatpublic disclosure of the data will “nudge”employers to reduce work-related injuries andillnesses in order to demonstrate to investors, job 2017

OSHAlogsWHO MUST COMPLY?Electronic reporting requirements are based on the size of an establishment. An establishment isdefined as a single physical location where business is conducted or where services or industrialoperations are performed. An employer may be comprised of one or more establishments.To determine if you need to provide OSHA with the required data for an establishment, you need todetermine the establishment's peak employment during the last calendar year. Each individualemployed in the establishment at any time during the calendar year counts as one employee, includingfull-time, part-time, seasonal, and temporary workers.Establishments required to keep OSHA injury andillness records must electronically submit informationfrom OSHA Forms 300, 300A and 301.Establishments required to keep OSHA injury and illnessrecords classified in industries with historically high ratesof occupational injuries and illnesses must electronicallysubmit information from OSHA Form 300A.Establishments currently required to keep OSHAinjury and illness records do not have to submitinformation electronically to OSHA under this rule. 2017

OSHAlogsWHICH INDUSTRIES MUST COMPLY?Over 250 EmployeesAll establishments with 250 or more employees in industries covered by the recordkeeping regulation mustelectronically submit to OSHA.20 to 249 EmployeesAll establishments with 20 to 249 employees in industries listed below, based on their NAICS code,must electronically submit to OSHA.NAICSIndustry DescriptionNAICSIndustry DescriptionAgriculture, forestry, fishing and hunting4921Couriers and express delivery services22Utilities4922Local messengers and local delivery23Construction4931Warehousing and storageManufacturing5152Cable and other subscription programmingLessors of real estate1131-33Wholesale trade53114413Automotive parts, accessories, and tire stores5321Automotive equipment rental and leasing4421Furniture stores5322Consumer goods rentalHome furnishings stores5323General rental centers4441Building material and supplies dealers5617Services to buildings and dwellings4442Lawn and garden equipment and supplies stores5621Waste collectionGrocery stores5622Waste treatment and disposal4452Specialty food stores5629Remediation and other waste management services4521Department stores6219Other ambulatory health care services4529Other general merchandise stores6221General medical and surgical hospitals4533Used merchandise stores6222Psychiatric and substance abuse hospitals4542Vending machine operators6223Specialty hospitals4543Direct selling establishments6231Nursing care facilities4811Scheduled air transportation6232Mental health and substance abuse facilities4841General freight trucking6233Community care facilities for the elderly4842Specialized freight trucking6239Other residential care facilities4851Urban transit systems6242Community food, housing and other relief services4852Interurban and rural bus transportation6243Vocational rehabilitation services4853Taxi and limousine service42442244514854School and employee bus transportation4855Charter bus industry4859Other transit and ground passenger transportation4871Scenic and sightseeing transportation, land4881Support activities for air transportation4882Support activities for rail transportation4883Support activities for water transportation7111Performing arts companies7112Spectator sports7121Museums, historical sites, and similar institutions7131Amusement parks and arcades7132Gambling industries7211Traveler accomdation7212RV parks and recreational camps7213Rooming and boarding houses7223Special food services4884Support activities for road transportation4889Other support activities for transportation8113Commercial and industrial machinery andequipment4911Postal service8123Dry-leaning and laundry services 2017

OSHAlogsWHAT DATA AND WHEN?The electronic submission requirements will be phased in according to the schedule below. The firstdue date is December 1, 2017. The data required to be submitted depends on establishment size.Compliance Date TimelineDecember 1, 2017 Required establishments with 250 or moreemployees must electronically submit informationfrom their 2016 OSHA Form 300A only. Next year,these establishments will also have to submit OSHA300 and 301 information. Required establishments with 20-249employees must electronically submit informationfrom their 2016 OSHA Form 300A only.March 2, 2019 Required Establishments with 250 or moreemployees must electronically submit informationfrom their 2018 OSHA Forms 300, 300A, and 301.July 1, 2018 Required Establishments with 250 or moreemployees must electronically submit informationfrom 2017 their OSHA Forms 300, 300A, and 301. Required Establishments with 20-249 employeesmust electronically submit information from their2017 OSHA Form 300A only. Required Establishments with 20-249employees must electronically submitinformation from their 2018 OSHA Form 300A only.Employers must submit data by March 2ndfor each following year. 2017

OSHAlogsWHAT DATA MUST I SUBMIT BY DECEMBER 1, 2017?The following information must be submitted for each required establishment. Data for eachestablishment should come from that establishment’s completed 2016 OSHA 300A Form.CompanyNameEstablishmentNameEstablishmentFull AddressSize ofEstablishmentEstablishmentTypeNAICS Code &Industry DescriptionOSHA Form300A YearAverage AnnualEmployeesTotal HoursWorkedTotal # ofDeath CasesTotal # of Caseswith Days Awayfrom WorkTotal # ofInjuriesTotal # of Caseswith Job Transferor RestrictionTotal # ofSkin DisordersTotal # ofOther RecordableCasesTotal # ofRespiratoryConditionsTotal # of DaysAway from WorkTotal # ofPoisoningsTotal # of DaysJob Transfer orRestrictionTotal # ofOther Illnesses 2017

OSHAlogsHOW WILL ELECTRONIC SUBMISSION WORK?On August 1, 2017, OSHA launched its Injury Tracking Application (ITA), a secure web site for theelectronic submission of OSHA recordkeeping information. You can choose between two methods tosubmit your injury data: Upload DataFor a quicker and simpler submission process, the ITA offers the option to upload a CSV filecontaining OSHA Form 300A data for all of your establishments at one time.For employers who track their OSHA records with, this CSV filewill be automatically generated for you. See the website formore information. Manual EntryFor those organizations without access to OSHA recordkeeping software, you will be required tocomplete a manual submission to OSHA. You will first need to add your establishments to theapplication by creating profiles for them. Once you have set up your establishments, you can thenenter and submit OSHA 300A data for each one via a web form. 2017

OSHAlogsHOW CAN OSHALOGS.COM HELP? Is a secure, web-based application that enables employers to create eachstate's first report of injury, track injuries, print all required OSHA reports, and view injurymetrics in also takes the guesswork out of electronic submission compliance bypreparing and creating the upload file required by OSHA. The file is pre-formatted and readyfor submission to OSHA with a simple click of a button.Want access to out to me at [email protected] OSHA Recordkeeping and Injury Intelligence Platform 2017

OSHAlogsFREQUENTLY ASKED QUESTIONS Are the electronic reporting requirements based on the size of the establishment or the firm?The electronic reporting requirements are based on the size of the establishment, not the firm. OSHA injuryand illness records are maintained at the establishment level. An establishment is defined as a single physicallocation where business is conducted or where services or industrial operations are performed. A firm may becomprised of one or more establishments. My company operates multiple facilities on a campus setting. Each facility has less than 250employees, but the campus has more than 250 employees. How should I count my employees todetermine if I have to electronically provide OSHA my injury and illness records?The recording and reporting requirements are establishment based. Under most circumstances, a campus is asingle physical location and considered as a single establishment. Under limited conditions, you may considertwo or more separate facilities that share a single location to be separate establishments. You may divide onelocation into two or more establishments only when:1. Each facility represents a distinctly separate business;2. Each facility is engaged in a different economic activity;3. No one industry description applies to the joint activities of the establishments; and4. Separate reports are routinely prepared for each establishment on the number of employees, theirwages and salaries, sales or receipts, and other business information. My firm has multiple establishments that do different things. Which determines whether Ihave to submit data for those establishments, the industry classification of the firm or theindustry classification of the establishment?The electronic reporting requirements are based on the industry classification of the establishment,not the industry classification of the firm. If a case occurs in one year but results in days away during the next calendar year, do Irecord the case in both years?No, you only record the injury or illness once. You must enter the number of calendar days away forthe injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If theemployee is still away from work because of the injury or illness when you prepare the annualsummary, estimate the total number of calendar days you expect the employee to be away fromwork, use this number to calculate the total for the annual summary, and then update the initial logentry later when the day count is known or reaches the 180-day cap. 2017

establishments covered by the recordkeeping regulation with 250 or more employees must comply. OSHA 300A data must be submitted to OSHA by December 1st, 2017. Some data will be posted on OSHA’s website for public consumption. Employers must upload their data via a CSV