Seyfarth Synopsis: OSHA reminded specific employers on Monday that the deadline for electronically submitting their 2017 Form 300A data to OSHA is July 1, 2018.
Electronic submission of 2017 Form 300A data is due by July 1, 2018 for establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in specific industries. Form 300As should be submitted using OSHA's Injury Tracking Application (ITA).
Each establishment's Form 300A for 2018 will be due March 2, 2019. We will continue to monitor OSHA's activities relating to this rule. OSHA has indicated that it will be reviewing the rule and will be issuing future guidance or revisions.
Employers operating facilities in state plan states should check with their local state plan office to confirm each individual state's e-filing requirements. For example, Kentucky OSHA requires e-filing using Federal OSHA's ITA, while the State of Washington has indicated that employers with facilities in Washington State are not required to e-file on Federal OSHA's ITA.
We have previously blogged concerning OSHA's contentious electronic reporting rules. See All State Plan Employers are Now Required to Electronically File 2017 Form 300A Data, OSHA Intends to "Reconsider, Revise, or Remove Portions" of Injury and Illness E-Reporting Rule Next Year, OSHA Delays Electronic Filing Date for Injury and Illness Records Until December 1, 2017, and Despite Lawsuit, OSHA Publishes Interpretation for New Workplace Injury and Illness Reporting Rule.
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