Washington Employers

WASHINGTON EMPLOYERS

Federal OSHA’s latest changes to the Occupational Injury and Illness Recordkeeping Rule now requires State Plan Employers to Electronically Submit their injury/illness records to Federal OSHA.

Annual Electronic Submission. Establishments in the following 2 categories are required to comply with the annual electronic submission requirements.

Category 1: Establishments with 250 or more employees at any time during the previous calendar year.

•  Table 3 applies to you

Category 2: Establishments with 20 to 249 employees at any time during the previous calendar year and are classified in an industry listed in Table 4 of Appendix B, chapter 296-27.

•  Tables 3 and 4 apply to you

Individual Data Collection: Upon Written Notification from Federal OSHA.

Applies to establishments that:

¨  Do not fit into either of the above 2 categories, or

¨  Are normally exempt because they meet the size and/or industry exemption.

•  Tables 3 and 4 DO NOT apply to you

Notes:

1.  Unlike the employee count for determining if you must comply with the recordkeeping requirements, electronic submission for category 1 2 establishments is based on the size of the establishment at a given location and not the entire firm. Therefore, only those establishments at locations having 250 or more employees (or 20-249 employees and are listed in Table-4 of Appendix B) must electronically submit their records to Federal OSHA. An establishment with fewer than 20 employees must only comply with the electronic submission requirements upon written notification from Federal OSHA.

2.  The electronic submission requirements do not change an employer’s obligation to complete and retain injury and illness records.

Required Action(s).

Category 1: You must electronically submit information from the following three recordkeeping forms to OSHA or OSHA’s designee once a year, no later than the reporting dates listed in Table-3 of the year after the calendar year covered by the forms:

¨  OSHA 300A Summary of Work-Related Injuries and Illnesses,

¨  OSHA 300 Log of Work-Related Injuries and Illnesses, and

¨  OSHA 301 Injury and Illness Incident Report

The only information on those forms you DO NOT provide is as follows:

¨  On the OSHA Log: Employee name (column B).

¨  On the OSHA 301 Incident Report:

ü  Employee name (field 1),

ü  Employee address (field 2),

ü  Name of physician or other health care professional (field 6),

ü  Facility name and address if treatment was given away from the worksite (field 7).

Category 2: You must electronically submit information from ONLY the OSHA Form 300A Summary of Work-Related Injuries and Illnesses to Federal OSHA or OSHA’s designee once a year, no later than the date listed in Table-3 of the year after the calendar year covered by the form. Example: For the year 2017, you’re submitting 2016 records no later than July 1, 2017.

Upon Written Notification.

Any establishment (even if exempt by size or industry classification) who receives written notification from Federal OSHA to electronically submit records must:

¨  Keep the injury and illness records required by chapter 27 and

¨  Submit information as directed by OSHA in the written notification.

Reporting Dates.

Establishments in categories 1 and 2 must submit annually following the records submission dates in Table-3.

Beginning in 2019, establishments in categories 1 2 must submit all required information by March 2 of the year after the calendar year covered by the form or forms. Example: submit by March 2, 2019, for the forms covering 2018.

Method of electronic submission.

For Category 1&2 establishments, OSHA will:

¨  Provide a secure Web site for the electronic submission of information.

¨  Not be notifying you about your routine/annual submittal.

For Individual Data Collections, OSHA will:

¨  Notify you by mail and include the Web site’s location in the notification.

¨  Announce individual data collections through publication in the Federal Register, the OSHA newsletter, and on their website.

Additional Information

1.  Contact Federal OSHA directly for questions or issues specific to their website or the link they’ll be providing for electronically submitting your records to them. OSHA will not accept paper copies. https://www.osha.gov/

2.  Washington State’s Division of Occupational Safety and Health (DOSH) recordkeeping rule is located at:

http://www.lni.wa.gov/safety/rules/chapter/27/

3.  OSHA’s recordkeeping rule is located at:

https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1904