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OSHA Recordkeeping: OSHA Only Requiring Electronic Submission of 300A Forms

By Tressi L. Cordaro and Kelli M. Winkle
  • June 18, 2018

In its latest Regulatory Agenda, the Occupational Safety and Health Administration (OSHA) indicated that it was undergoing rulemaking to revise the “Improve Tracking of Workplace Injuries and Illnesses” regulation promulgated under the Obama Administration. OSHA noted it was considering deleting the requirement for employers with 250 or more employees at an establishment to electronically submit its 300 Log, 301 Forms, along with the 300A Form.

Recently, OSHA made clear that it will not collect or require employers with 250 or more employees per establishment to submit the 300 Log or the 301 Forms. OSHA will require all employers covered by the regulation to submit only the 2017 300A Form by July 1, 2018. Beginning in 2019, and every year thereafter, the 300A Forms must be submitted by March 2.

According to OSHA, “OSHA is not accepting Form 300 and 301 information at this time.” The agency announced it will issue a notice of proposed rulemaking (NPRM) to reconsider, revise, or remove provisions of the “Improve Tracking of Workplace Injuries and Illnesses” final rule, including the collection of the Forms 300/301 data.

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©2018 Jackson Lewis P.C. This Update is provided for informational purposes only. It is not intended as legal advice nor does it create an attorney/client relationship between Jackson Lewis and any readers or recipients. Readers should consult counsel of their own choosing to discuss how these matters relate to their individual circumstances. Reproduction in whole or in part is prohibited without the express written consent of Jackson Lewis.

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