Deadline Near for OSHA’s e-Report Submission: 01 July 2018

Phase 2 of OSHA’s new Electronic Submission of Injury and Illness Records comes due 01 July 2018 for the reporting of your OSHA 300 records for 2017. The text for the entire rule is found at [29 CFR 1904.41]

Phase 1 of the new e-Reporting rule required you to submit 2016’s reports electronically to OSHA by December of 2017. Hopefully, you got that done on time. But either way, Don’t Panic. The actual reporting process is simple, even if you have dozens of facilities.

Here are the steps in as brief an explanation as I could manage.

1. Determine Applicability – The first step is to determine if this requirement is applicable to your company. There are three “Brackets” of companies that must e-Report.

a. All companies with 250 employees or more (the upper bracket).

b. All companies that have 20 to 249 employees AND whose NAICS numbers are on a special list (the lower bracket).

c. Any individual company notified in writing by OSHA that they must e-Report.

Be Aware – OSHA has a particular way of counting employees. I call it the “at any time” method. For example, if your company usually has about 230 employees during 2017, but you bumped up to 250 or more for even one day, then you are in the upper bracket for Illness and Injury reporting. If your company averaged around 15 for 2017, but you had 20 or more on the payroll “at any time”, then you have been bumped up into the lower bracket for Electronic Reporting and you are subject to the new e-Reporting requirement.

“Employees”, by the way, are people that work for the company, “… whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers.”

The NAICS List – This is a list of specific industries that OSHA feels are worthy of more scrutiny because of the elevated level of risk to employee health and safety. So, if you have 20 to 249 employees during the reporting year and your company operates under one of the NAICS numbers, then you are required to e-Report. The NAICS list is included at the end of this article, and can also be found here: [THE NAICS LIST] .

2. Get Your OSHA 300A Form. To submit the information required by the e-Reporting rule, you will need to have your OSHA 300A form for 2017 on hand. All the information you need for the e-Report is on that form.

By the way, don’t forget to post that same form as required in [29 CFR 1904.32(b)(5)] – It needs to be displayed publicly where other employee notices are routinely posted.

3. Go To The Website. OSHA has created a specific place where you can submit your data. Go to the “Injury Tracking Application” page at [OSHA ITA Page]. Here you will find some instructions if this is your first visit. It is an unusually straightforward process, so it shouldn’t take long to figure out how to use it.

When you’re ready, click the blue “Launch ITA” button at the top right of the page. That will bring you to the login page. Click “Create an Account” if you don’t have one yet. That will require some very basic information on your facility and yourself. You will get an email asking to confirm the account.

Once you have an account established, you must enter some more specific information about your facility by clicking the “Create Establishment” button. You will have to give your facility a nickname if you have more than one location (ACME #217 for instance), then the official company name, and you will need your NAICS for this page. For each company location where employees work, you will have to create a separate establishment.

4. Data Entry. Now, you can enter the data from your OSHA 300A log. OSHA has 3 ways to do this.

a. You can manually fill in the data on the webform. Suitable if you just have one or two locations.

b. You can upload a CSV file with the required information for your location(s).

c. You can use your in-house or on-line recordkeeping software to upload the information, but those may not all work at this time.

After you have entered and carefully confirmed your data, then you submit the form to OSHA. You will get an email confirming the submission, but I recommend you also get a screenshot of the webpage showing the successful submission. Print these pages out and staple them together with your 300A form for permanent filing.

My hope is that this article has been helpful. I did it because my mission is to help the hyper-regulated business owners and managers of America deal with the burden of compliance with the OSHA, EPA and DOT regulations.

You are invited to take my Quick Compliance Assessment and see the 19 common compliance mistakes that most companies make. Go to [Compliance Assessment Link]

I may be contacted at (843) 599-0330 or by RHarvey@EchelonEHS.com .

THE LIST: Companies who operate under these NAICS codes and have from 20 to 249 employees are required to electronically report their annual records of injuries and illnesses to OSHA.

NAICS

Industry

11

Agriculture, forestry, fishing and hunting.

22

Utilities.

23

Construction.

31-33

Manufacturing.

42

Wholesale trade.

4413

Automotive parts, accessories, and tire stores.

4421

Furniture stores.

4422

Home furnishings stores.

4441

Building material and supplies dealers.

4442

Lawn and garden equipment and supplies stores.

4451

Grocery stores.

4452

Specialty food stores.

4521

Department stores.

4529

Other general merchandise stores.

4533

Used merchandise stores.

4542

Vending machine operators.

4543

Direct selling establishments.

4811

Scheduled air transportation.

4841

General freight trucking.

4842

Specialized freight trucking.

4851

Urban transit systems.

4852

Interurban and rural bus transportation.

4853

Taxi and limousine service.

4854

School and employee bus transportation.

4855

Charter bus industry.

4859

Other transit and ground passenger transportation.

4871

Scenic and sightseeing transportation, land.

4881

Support activities for air transportation.

4882

Support activities for rail transportation.

4883

Support activities for water transportation.

4884

Support activities for road transportation.

4889

Other support activities for transportation.

4911

Postal service.

4921

Couriers and express delivery services.

4922

Local messengers and local delivery.

4931

Warehousing and storage.

5152

Cable and other subscription programming.

5311

Lessors of real estate.

5321

Automotive equipment rental and leasing.

5322

Consumer goods rental.

5323

General rental centers.

5617

Services to buildings and dwellings.

5621

Waste collection.

5622

Waste treatment and disposal.

5629

Remediation and other waste management services.

6219

Other ambulatory health care services.

6221

General medical and surgical hospitals.

6222

Psychiatric and substance abuse hospitals.

6223

Specialty (except psychiatric and substance abuse) hospitals.

6231

Nursing care facilities.

6232

Residential mental retardation, mental health and substance abuse facilities.

6233

Community care facilities for the elderly.

6239

Other residential care facilities.

6242

Community food and housing, and emergency and other relief services.

6243

Vocational rehabilitation services.

7111

Performing arts companies.

7112

Spectator sports.

7121

Museums, historical sites, and similar institutions.

7131

Amusement parks and arcades.

7132

Gambling industries.

7211

Traveler accommodation.

7212

RV (recreational vehicle) parks and recreational camps.

7213

Rooming and boarding houses.

7223

Special food services.

8113

Commercial and industrial machinery and equipment (except automotive and electronic) repair and maintenance.

8123

Dry-cleaning and laundry services.