2017 OSHA Injury Tracking of Electronic Submission of Injury and Illness Records
By Ruth Kiefer, Loss Control Manager, MSc, ARM
As I know many of you have just finished submitting your 2016 injury data that was either submitted on a 300A or 300 injury log onto the OHSA website this past December. But I want to remind you that you will also need to submit your 2017 injury data as well. If you are a covered establishment (determined by your NAICS code), you may start submitting either the 300 or 300A now through April 1, 2018.
Just to recap the requirements for you:
Who’s Required: Establishments with 250 or more employees that are currently required to keep injury and illness records (All NAICS codes), establishments with 20 – 249 employees with select NAICS codes, and those with fewer than 19 employees or less, may continue to maintain your injury and illness records without having to submit them to the OSHA website.
What are you submitting: Covered establishments with 20 – 249 employees will submit their Form 300A, those with 250 or more, will submit the complete OHSA Form 300.
When: You will submit your 2017 injury data from now until April 1st. This will be a continuous date of uploading the information for future years.
How: OHSA has provided a secure website that offers three options for data submission. First, users can manually enter data into a web form. Second, users can upload a CVS file to process single or multiple establishments at the same time. Finally, if you have an automated recordkeeping system, you will have the ability to transmit data electronically via an application program interface (API).
Where do I get additional information? OHSA has created a “landing page” for you with a list of links that contain instructables for getting started, how to upload, how to set up an account. The link is: www.ohsa.gov/injuryreporting/index.html
In the meantime, here are answers to some of the more common questions we’ve been getting for the past upload event:
May a firm with multiple establishments make a single submission of the data from the multiple establishments?
Yes, a firm with more than one establishment may submit establishment-specific data for multiple establishments. To do this, the firm will create one registration and follow the directions provided to submit data for multiple establishments. It is important to note that the electronic reporting requirements are for data at the establishment level, not the firm level. The submitted data must be specific for each individual establishment.
If my establishment is selected to respond to the Bureau of Labor Statistics Annual Survey, do I have to give the same information to both Agencies?
Yes. At this time, OSHA and the BLS are working to identify and minimize the burden on employers that are required to respond to both data collections. However, until they have this worked out, you will need to provide both agencies with the required data through their separate collection vehicles.
My company operates multiple facilities on a campus setting. Each facility has less than 250 employees. How should I count my employees to determine if I have to electronically provide OHSA my injury and illness records?
The recording and reporting requirements of Part 1904 are establishment based. Under most circumstances, a campus is a single physical location and considered as a single establishment. Under limited conditions, you may consider two or more separate facilities that share a single location to be separate establishments. You may divide one location into two or more establishments only when: 1) Each facility represents a distinctly separate business; 2) Each facility is engaged in a different economic activity; 3) No one industry description applies to the joint activities of the establishments; and 4) Separate reports are routinely prepared for each establishment on the number of employees, their wages and salaries, sales or receipts, and other business information.
This is a confusing regulation, so please call your Loss Control Representative if we can help you in any way.
