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Targeted inspections stress importance of record-keeping compliance

Posted On: Nov. 4, 2018 12:00 AM CST

Employers should pay more attention to complying with electronic record-keeping requirements now that the U.S. Occupational Safety and Health Administration is launching a site-specific inspection program targeting employers the agency believes should have, but did not, electronically submit certain injury and illness data for calendar year 2016, experts say.

The program will target high-injury-rate establishments in both the manufacturing and nonmanufacturing sectors for inspection, the agency said Oct. 17.

Under this program, the agency will perform inspections of employers the agency believes should have provided Form 300A data but did not for the calendar year 2016 injury and illness data collection, which OSHA required employers to electronically submit by Dec. 15, 2017. The calendar year 2017 deadline was July 1, 2018, but employers can still provide information to the database.

“OSHA hopes the move will boost electronic record-keeping compliance as barely half of employers who are required to submit OSHA Form 300A have actually done so,” Courtney Malveaux, a principal in the Richmond, Virginia office of Jackson Lewis P.C., said in a blog post Oct. 23.

Going forward, organizations with 250 or more employees currently required to keep OSHA injury and illness records and organizations with 20 to 249 employees classified in specific industries with historically high rates of occupational injuries and illnesses will be required to provide this information each year by March 2.

“Manufacturers, energy and utility companies, trucking and transportation companies and other employers engaged in nonconstruction activities should make sure they are getting those 300A Forms filed by the deadline each year,” Mr. Malveaux said.

In July, OSHA proposed amending the rule to rescind the requirement for employers to electronically submit data from OSHA forms 300 and 301 but still require Form 300A data submissions.