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OSHA may scale back electronic injury reporting requirements

April 5th, 2018 by Jay Finegan, CHMM

OSHA may scale back electronic injury reporting requirements

The Occupational Safety and Health Administration repeatedly extended the due date for businesses to upload their 2016 injury data to its national database, settling on a final deadline of Dec. 30, 2017. Although the federal health and safety watchdog has set a submission deadline of July 1 for organizations to share relevant injury information from 2017, OSHA may change its requirements in terms of the specific forms and records to be reported. The result would be a less cumbersome and intrusive process that requires less from businesses.

OSHA may change types of injury information required for online submission

"It's possible OSHA may only require form 300A in the future."

Currently, OSHA requires many businesses to share the 300A, 300 log and 301 injury report forms to be in compliance with established recordkeeping regulations. However, the agency only mandated delivery of the 300A form, the summary of work-related injuries and illnesses, for 2016 information, as law firm Husch Blackwell pointed out. More importantly for businesses, OSHA may continue with this more limited requirement going forward.

Law firm Jackson Lewis P.C. said the privacy concerns on the part of business owners related to some of the data-sharing requirements could lead to a change on OSHA's part. Forms 300 and 301 both contain personally identifiable information (PII), tying individual employees to specific injuries and illnesses. OSHA, which originally said it would release aggregated information about workplace health outcomes but omit any PII, more recently admitted it couldn't guarantee its ability to protect the PII data, which means it couldn't publicly release it.

This turn of events could lead to OSHA to require only the 300A forms, which don't contain PII, from here on out. Such a change allows OSHA to fulfill its reporting expectations, while avoiding the risk of inadvertent release of personal information. The good news is that this change simultaneously reduces the burden for companies in terms of assembling and reporting information.

It's important to remember that this is only a potential, although somewhat likely, policy change for OSHA and not yet a confirmed plan. Businesses required to submit such information should continue to look for updates regarding reporting requirements so they can proceed forward in the most effective and compliant way. Affected companies should prepare to submit all three injury reporting forms in case OSHA doesn't follow through on the expected plan, but also be ready to pivot and report only 300A data if the change occurs.

Jay Finegan, CHMM

Jay Finegan, CHMM

Compliance Services Leader

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