OSHA’s Electronic Submissions & Anti-Retaliation Rule
- Large employers (i.e., establishments with 250 or more employees that are not exempt from OSHA’s recordkeeping rules)
- “High-risk” employers (i.e., establishments with 20-249 employees in certain high-risk industries)
- Any other employers from which OSHA makes a written request for data
| July 1, 2017 | July 1, 2018 | |
|---|---|---|
| Non-Exempt Employers with 250+ Employees | 2016 OSHA Form 300A Logs due | 2017 OSHA Forms 300, 300A and 301 due |
| Employers in “High Risk” Industries with 20-249 Employees | 2016 OSHA Form 300A Logs due | 2017 OSHA Form 300A Logs due |
- Employers subject to OSHA’s recordkeeping regulations can take certain steps now to comply with the new rules and limit citation liability:
- Collect OSHA 300A forms (and 300 and 301 forms for large employers) electronically.
- Post the newly revised OSHA poster to ensure compliance with the rule’s revised informational requirements.
- Ensure reporting procedures (and, if applicable, any safety incentive programs) to ensure that such programs are reasonable and do not discourage injury and illness reporting.
- Remind managers of anti-retaliation practices in light of the increased scrutiny employers will face under the revised rule. Per OSHA’s guidance, review disciplinary, incentive and drug-testing programs for elements that could result in retaliatory actions against employees.
