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12/12/2017 | 2 MINUTE READ

NASF Compliance Alert: Companies Must Electronically File Injury and Illness Reports by this Friday, Dec. 15

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The National Association for Surface Finishing is reminding finishing companies that you may be required to electronically file your 2016 injury and illness summary report to OSHA by this Friday, December 15.

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The National Association for Surface Finishing is reminding finishing companies that you may be required to electronically file your 2016 injury and illness summary report to OSHA by this Friday, December 15.

OSHA has estimated that more than 450,000 companies nationwide must submit their 2016 Form 300A data under the agency’s recently accessible tracking system – the Injury Tracking Application (ITA)  here if you meet the following criteria:

  • Large Companies – If you have 250 or more employees and are currently required to keep OSHA injury and illness records.
  • Small and Medium-Size Companies – If you have 20-249 employees and are classified in certain industries with historically high rates of occupational injuries and illnesses. This category includes most manufacturing operations, including companies in the surface finishing industry.

All operations currently regulated under OSHA federal and state plans are required to report this week. However, the following OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY. Establishments in these states are not currently required to submit their summary data through OSHA’s new tracking system.

Background: On May 12, 2016, OSHA published a final rule (81 FR 29624) with an effective date of January 1, 2017, for the agency’s new electronic reporting requirements. Under these requirements, certain employers were required to electronically submit 2016 Form 300A data to OSHA by July 1, 2017. The original July 2017 submission deadline was delayed to December 1, 2017 for several reasons, and OSHA’s new web-based reporting system was not made available until August 2017.

The most recent November 24, 2017 notice from OSHA announced the agency’s decision to extend the reporting deadline to December 15, 2017, and can be found here.

Outlook: OSHA’s original electronic reporting rule remains under review in federal court. Several major provisions of the rule were challenged, including  federal whistleblower and employer anti-retaliation requirements that could pose significant challenges and new liabilities for businesses. Two separate lawsuits have been on hold since this past summer as the litigants, which include the U.S. Chamber of Commerce and National Association of Home Builders, wait to see what decisions OSHA will make under the new administration. The White House’s nominee to head OSHA, Scott Mugno, recently FedEx’s Vice President for Safety, Sustainability and Vehicle Maintenance, has not yet been confirmed by the full Senate.

For further information, please contact Jeff Hannapel at jhannapel@thepolicygroup.com

 

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