New OSHA Reporting Requirements in Effect Now!

November 21, 2017

OSHA’s new electronic reporting standard requires employers with over 250 employees in a location or employers in certain industries with between 25 and 249 employees to report their OSHA 300A data electronically by December 1st, 2017. Industries are defined by their NAICS Code (see listing at the end of the document linked below).  Please note, however, “electronic reporting requirements are based on the size of the establishment, not the firm, OSHA injury and illness records are maintained at the establishment level.  An establishment is defined as a single physical location where business is conducted or where services . . . are performed.”  It is, therefore, for VNPP Members the exception, not the rule, to have 20+ employees in one location; there will be some exceptions, larger providers with more than 20 individuals in their main office location, larger day services, and a few larger residential facilities. OSHA has set up a portal for the data submission.  Attached are documents to assist you with the registration and submission of data.  Initial reports from communities who have submitted information indicate that the process this year isn’t too bad. Next year the deadline is July 1, and some locations will have to provide additional data. Information on OSHA injury recording has also been included in the attachment for your use.  A separate attachment on reporting requirements in Virginia for severe injuries has been included for your reference Electronic Submission of Injury Data