Seyfarth Synopsis: As most
employers probably know by now, OSHA's revised recordkeeping
rule requires certain employers to electronically file injury and
illness data with OSHA. Originally the reporting deadline was July
1, 2017. OSHA has again extended the deadline, this time to December
15, 2017.
During the previous extension period, it appeared that OSHA
might be reconsidering the rule, with a possibility of
modifications or a complete revocation of the rule by December 1,
2017. However with the recent extension to December 15, it appears
that the rule will remain unchanged for the time being and that
covered employers must report by the new deadline.
As a reminder, establishments with 250 or more employees must
submit information electronically from their 2016 Form 300A by
December 15, 2017. These same employers will be required to submit
information from all 2017 forms (300A, 300, and 301) beginning in
2018.