OSHA Proposes Amending Electronic Recordkeeping Requirements

On July 30, 2018, the Occupational Safety and Health Administration (OSHA) published a notice of proposed rulemaking (NPRM) in the Federal Register seeking comments on a proposed measure that would partially rescind the 2016 amendments to its recordkeeping rule. The 2016 amendments required establishments with at least 250 employees, or with at least 20 employees in a high-risk industry, to electronically submit their illness and injury records to OSHA annually, beginning in 2017. However, OSHA was not accepting OSHA 300 and 301 forms on its portal for the July 1, 2018, deadline. 

What Employers Need to Know About the Proposed Amendment

What OSHA proposes to change:

• Employers with at least 250 in a single establishment would no longer need to electronically file (e-file) 300 and 301 logs (but they would still need to e-file the 300A summary annually). The reason for this change given in the proposed rule is that collection of the 300 and 301 logs