OSHA’s New Recordkeeping Rule

Your injury and illness records are about to become public record!


The Occupational Safety and Health Administration (OSHA) has issued another final rule this year. This new rule on facility recordkeeping will require employers to electronically submit injury and illness data to OSHA each year. The data submitted will be made public as part of an OSHA public records database. This change, as expected, is causing much controversy with employers throughout general industry sectors.

The new rule will require facilities with 250 or more employees to electronically submit their injury and illness information, from OSHA forms 300, 300A, and 301, to OSHA each year. Facilities with 20 to 249 employees, in certain high-hazard industries, will need to submit the information from their OSHA 300A form. The information that facilities submit will be made available on OSHA’s website. OSHA says that this database will “enable researchers to better study the causes of injuries, identify workplace hazards before they become widespread, and evaluate the effectiveness of injury and illness prevention programs and techniques.”

These requirements took effect August 10, 2016, and will be phased in over the next two years. The facilities with 250 or more employees are to submit information from their 2016 Form 300A by July 1, 2017. These same facilities will be required to submit information from their 2017 Forms 300A, 300, and 301 by July 1, 2018. Starting in 2019, the information is to be submitted by March 2 of each year after that. Facilities with 20-249 employees, in certain high-risk industries, must submit information from their 2017 Form 300A also by July 1, 2018. Starting in 2019, the information is to be submitted by March 2 of each year after that.

Another controversial aspect to the new rule is that OSHA will be further scrutinizing the use of Safety Incentive Programs (e.g. if a company goes a full year without a reported injury or illness, there will be an extra bonus in everybody’s paycheck). This is going to be done because, according to OSHA, it discourages employees from reporting properly. This has been under debate for some time now. OSHA says that this kind of incentive program is more likely to discourage employees from reporting out of fear of angering or disappointing fellow coworkers who will be denied the incentive.

Why a New Rule

According to OSHA, one of the reasons for this new rule is to “encourage employers to increase their efforts to prevent worker injuries and illnesses, and, compelled by their own incentives spirit, to race to the top in terms of worker safety.” While some people feel that the new OSHA injury reporting rules will bring workplace injury and illness reporting into the 21st century, some others, including the U.S Chamber of Commerce, believe that “the rule will only create a new filing requirements that will lead to sensitive employer data being made public without context or explanation.” Without proper context behind injury and illness data, employers could be seen as unsafe, and it may not reflect a company’s commitment to establishing and maintaining a safe work environment.

Will this new rule and requirements change the safety culture within the workplace for the good? That has yet to be determined. The new rule is set to be in full effect, with the requirements being phased in over the next two years.

For more information regarding the “High-Risk” industries, you can read our newsletter article from Winter 2015. If you have any questions regarding your company’s reporting requirements, please contact Conversion Technology Inc. or visit our website at conversiontechnology.com.

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