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OSHA Recordkeeping Update and Recommendation

Friday, August 4, 2017
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On August 1, OSHA announced the portal to electronically report information from the OSHA 300A forms was available. Many employers mistakenly believe they must provide this information immediately or risk citations and penalties.

The link below is to the section of OSHA’s website where the electronic recordkeeping portal is located: https://www.osha.gov/injuryreporting/

CAUTION! The deadline by which this information must be submitted was extended to December 1, 2017. The link below to the Federal Register is the official notification extending the deadline to at least December 1, 2017.

https://www.federalregister.gov/documents/2017/06/28/2017-13550/improve-tracking-of-workplace-injuries-and-illnesses-proposed-delay-of-compliance-date

Many employer and business groups objected to aspects of the electronic recordkeeping standard and a number of lawsuits have been filed on behalf of these groups. The new administration is considering their options to revise or remove provisions in the final rule.

We are cautioning against providing OSHA log information on the website until the status of the extension and lawsuits is better understood. It is difficult to “undo” information you provide to the agency, so our advice is to wait until we draw closer to the current December 1 deadline. Compliance deadlines for other new standards continue to be pushed further into the future as the administration attempts to revise and/or remove the more difficult and controversial provisions in each standard.

We are watching these developments closely and will update you if or when any changes occur. There are legal complexities and challenges in making changes to regulations, so additional delays may be necessary to work out all of the details. If you have any questions, please contact us by phone or email. 

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

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