The deadline for OSHA online reporting (workplace accident illnesses and injuries) is imminent. Unless there is another unlikely delay, that deadline is this Friday, December 15, 2017. OSHA is implementing a new era of efficiency and compliance accountability. How does this effect Establishments using temporary staffing services?
OSHA reporting, now online, is the responsibility of the establishment.
Online Injury Reporting
Understanding this critical aspect of shared liability is the first step. In brief, you should be aware of how online OSHA Injury Reporting changes affect you. This blog does not replace doing your research – but is a guide to get you started. The list below is not exhaustive, and you should review the OSHA website and heed the guidance of your workers compensation liability insurance provider. The basics:
- Establishments with 250 or more employees (larger employers) that reported injury or illness records in the prior year are required to routinely submit OSHA reporting data online. And Establishments with 20-249 employees (smaller employers) in OSHA-named industries (see OSHA website for complete list).
- The full list of industries is long, but some primary industries are: Manufacturing, Agriculture, Retail, Construction, Medical Facilities, Warehousing and storage, Transportation, Utilities, Auto Parts, Waste Collection, Entertainment and more.
- First submission in December requires, under the new online reporting rule, submitting the 2016 OSHA 300A “Summary of Work Related Injuries and Illnesses.” Note: Exceptions include the establishment can omit the employee name, and several personal detail fields.
- How and where you submit the data is typically by CSV (comma delimited format easily exported from Microsoft XL) file upload – or some automated OSHA record keeping solutions have developed direct links via OSHA’s API’s. Check with your provider if this pertains to you.
- Reported information is nothing new in terms of the records kept and reported. It is only new in terms of how establishments are submitting the data to OSHA and the resulting efficiency and effectiveness overall.
- You are an “establishment” in the eyes of OSHA if your business “is a single location where business is conducted or where services or industrial operations are performed…” See the full definition at 29 C.F.R. 1904.46 or ask your safety and health risk manager for more detail.
- Future reporting submissions are scheduled. For larger employers after the December 15th, 2017 initial reporting, establishments must submit the OSHA Summary Form 300A; the detailed OSHA Form 300, “Log of Work-Related Injuries and Illnesses” OSHA; and the OSHA Form 301, the “Injury and Illness Incident Report” describing individual incidents in detail. Smaller employers participating in OSHA-identified industries must submit a summary 300A form.
- Exceptions for filtering some personal information (see 3, above) apply to these reports – and your establishment will need to implement a process to filter that information from your internal reports, prior to submitting online to OSHA.
- There are more deadlines, including July 1, 2018 for submitting 2017 data and March 2, 2019 for 2018 data. OSHA is allowing 2 years for establishments to learn and become accustomed to the new online reporting system. After reporting data for 2018, the annual deadline for the prior year’s data (2019 and beyond) is March 2nd, of the following calendar year.
Prepare for changes. As establishments engage in the new reporting rules, its likely that feedback and process improvement loops may generate some changes. Your safety and risk manager should be watching OSHA announcements.
Privacy and reported information. Establishments should be aware that electronic filing is going to post data publicly. This means employers need to filter personal privacy (individually identifiable) information that was otherwise often submitted to OSHA in the past in order to protect individual employment and health records. Online OSHA reporting does not preclude diligence in following privacy law.
Safety records are now public. Establishments will now find that their safety record is public record. While many injury and illness reports make Front Page News, now all records are in an accessible OSHA public database. OSHA’s intent is not to shame employers, but to raise the focus and attention on safety and prevention overall. Even so, the change makes it worth a conversation with your corporate marketing and PR people.
Barton Staffing Solutions has had a focus on safety now going on two decades. We can advise clients on best practices, and regularly participate in our client’s own safety committees. This blog is not exhaustive, but is a good start if you are still unsure of the new world of OSHA online reporting. Call us today with your questions as they pertain to staffing and we can help.