UPDATE: OSHA has delayed the deadline by an additional two weeks until Dec. 15. Click here for the official announcement from OSHA.
This December 1 is the deadline set by the Occupational Safety and Health Administration (OSHA) that requires medium to large contractors in certain industries, to provide injury, illness, and incident information using the new Injury Tracking Application (ITA).
For 2017, contractors of 20–250+ employees in affected industries will need to file information from the 2016 OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) using the ITA. In 2018, the procedure will be somewhat different. Companies with 250 or more employees will be required to submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses), Form 300A, and Form 301 (Injury and Illness Incident Report). Companies in qualifying industries with 20–249 employees will need to supply information from only Form 300A. The deadline for 2018 is July 1. Each subsequent year's deadline will be Mar. 2.
According to Wesley Wheeler, NECA's Director of Safety, there was a lingering question as to whether Congressional action would intervene and rescind the rule. Congress has not acted to date. This rule is in effect and NECA continues to monitor this rule and will provide an update if anything changes.
California, Maryland, Minnesota, South Carolina, Utah, Washington and Wyoming, however, have not yet adopted this requirement. Certain governments in Illinois, Maine, New Jersey and New York also are not requiring submissions through the ITA. Contact information for each state plan is available using this tool. More information on when these states will require electronic filing is forthcoming.
There are multiple options for formats in which companies may supply the information. For details, visit https://www.osha.gov/injuryreporting/index.html.
In May of 2016, OSHA published the rule titled, "Improve Tracking of Workplace Injuries and Illnesses," which required certain employers to submit information from their 2016 Form 300A electronically. The effective date of the rule was Jan. 1, 2017, and the initial deadline was July 1, 2017. OSHA delayed the initial submission deadline to Dec. 1, 2017.
OSHA's stated reason for the delay was to enable the new presidential administration the opportunity to review the new requirements prior to implementation. It also stated a delay would benefit affected organizations with more time to prepare. In its proposed delay, OSHA also stated at the time that the reporting system would not be available until Aug. 1, so the delay ended up being necessary for all affected parties.
The application is now available at https://www.osha.gov/injuryreporting/index.html.