Following the blog released last week regarding OSHA’s new e-report submission, Poms Connects has had several questions concerning affected employers’ requirements if they reside in a state that has a State Plan but has not completed adoption of their own state rule. We have updated the blog to reflect that question, for more information please click here.
July 1, 2018 was the due date for OSHA’s new Electronic Submission of Injury and Illness Records, the reporting of your OSHA 300 records for 2017.
The first step to make is to determine if this applies to your company. If you are a company with 250 or more employees, OR if you’re a company with 20-249 employees and whose NAICS numbers are on a special list, OR if you are an individual company who has been notified in writing by OSHA that you must e-Report, then this announcement is for you.
NOTE: OSHA has also determined that Section 18(c)(7) of the Occupational Safety and Health Act, and relevant OSHA regulations pertaining to State Plans, require all affected employers to submit injury and illness data in the Injury Tracking Application (ITA) online portal, even if the employer is covered by a State Plan that has not completed adoption of their own state rule. An employer covered by a State Plan that has not completed adoption of a state rule must provide Form 300A data for Calendar Year 2017.
It is important to keep in mind that OSHA counts employees uniquely. For example, if your organization had about 230 employees in 2017 but for even one day you had employed 250 employees, then this announcement applies to you. Employees are people that work for the company whether “they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers.”
This also applies if your company is on the NAICS list, which is a list of specific industries OSHA has deemed worthy of scrutiny due to the high level of risk to employee health and safety.
All employers covered by OSHA’s electronic recordkeeping requirements are required to submit data from their calendar year 2017 300A form (Annual Summary of Work-Related Injuries and Illnesses). This can be done by using OSHA’s Injury Tracking Application (ITA), where there are three options for submissions:
- Enter the data manually;
- Upload a CVS file to process single or multiple establishments at the same time; or
- Transmit data electronically via an application programming interface (for users of automated recordkeeping systems).
The process is straightforward, and if it is your first visit to the page you will receive instructions. 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.
Once that is done, you can begin entering your organization’s data from your OSHA 300A log. 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.