OSHA Electronic Record-Keeping Rule – July 1, 2017 Compliance Deadline

OSHA Electronic Record-Keeping Rule – July 1, 2017 Compliance Deadline

April 2017

OSHA Final Rule to Improve Tracking of Workplace Injuries, effective January 1, 2017, requires nursing facilities to electronically submit the employee injury and illness data that they are required to record on their onsite OSHA Injury and Illness forms.

According to OSHA, the purpose of this rule is twofold:

  • Electronic submission will better enable OSHA to analyze the data;
    • Electronic submission will enable OSHA to make public the information by posting it to the OSHA website thereby “shaming” or “encouraging” employers to improve workplace safety.

Nursing facilities with 250 or more employees must submit information from their 2016 Form 300A by July 1,2017 and from all 2017 forms (300A, 300, and 301) by July 1, 2018.  Beginning in 2019 and every year thereafter,the information must be submitted by March 2.

Nursing facilities with 20 to 249 employees must submit information from their 2016 Form 300A by July 1, 2017 and their 2017 From 300A by July 1, 2018.  Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Employers must plan to be in compliance with the new rule despite a federal lawsuit filed in Texas challenging the legality of the new OSHA rule.  According to the Court’s Order, the lawsuit will not be decided until after the July 1, 2017 compliance deadline for employers. 

For more information about the new Rule and its requirements, see https://www.osha.gov/recordkeeping/finalrule/