Are you ready to mail your OSHA 300 form? You might want to hold the stamp. As of this year, OSHA requires that establishments with 250 or more employees must submit electronically. Forms 300, 300A, and 301–which summarize job-related injuries and illnesses logged during the 2017 calendar year–all must be digitally provided to OSHA on or before July 1, 2018. Establishments with 20-249 workers in certain high-injury rate industries will need to electronically submit Form 300A by that same time.
OSHA has built a secure website that offers three different ways to submit data:
- Manually enter data via webform
- Upload a CSV file
- Transmit data electronically via an API if you have an automated recordkeeping system.
If you’re still tabulating injury data by hand, you’re lucky to have the extra time until July. Beginning in 2019, the deadline will be bumped up to March 2. The quickest and most effective option is to maintain data in an automated program and transmit directly via API. It ensures that injury data is recorded accurately and can be accessed easily. Further, digital data can be more easily analyzed within your organization to look for leading indicators that might further improve your safety culture.
OSHA intends to use this process to “nudge” employers into reducing injury and illness in the workplace by publicizing some of the data on the agency’s website. They believe that these new requirements will have the same effect as the requirement for restaurants to post their health department sanitation scores–to encourage better safety practices through public exposure. Additionally, the large trove of data, which will be scrubbed of personally identifiable information, will be a boon to researchers studying injury causality, safety hazards, and the efficacy of injury prevention programs. Finally, the rule prevents employers from retaliating against workers who report an illness or injury.
And don’t forget, employees have an obligation to post a copy of the 300A form in a common area where employees can see it. You will often see this in a break room or common area where other federally mandated notices (like information on the Fair Labor Standards Act, Equal Employment Opportunity, and the Family and Medical Leave Act) are located. It must be posted until April 30, 2017, and failure to comply can lead to censure or fines.
Why does OSHA require a public posting? As surprising as it might be to readers in leading safety cultures, not every company has a stellar safety record. Worse, some organizations actively cover their safety tracks. The requirement to post OSHA 300A, along with other provisions like whistleblowing protections and the general duty clause, can be an important tool to inform workers about conditions in their own workplaces.
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