New 2017 OSHA Injury & Illness Electronic Data Reporting and Submission

As of 2017, OSHA’s revised injury and illness on-the-job reporting submission requirements took effect for certain companies, including the home healthcare and staffing industries. The new requirements are outlined below, courtesy of Key Risk, our Workers’ Compensation insurance carrier partner for temporary staffing employers, including medical and non-medical staffing firms for home health care and hospice.

Under the revised final rule, employers that fall under the following two categories are now required to electronically submit the data they already collect to OSHA, which in turn will publish the information on its website:

  • Employers with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries & Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report). There is a phase-in requirement process for these establishments: 300A Summaries for 2016 must be electronically submitted by July 1, 2017; OSHA Forms 300, 300A, and 301 for 2017 must be electronically submitted by July 1, 2018.
  • Operations with 20-249 employees in high-hazard industries with historically high rates of occupational injuries and illnesses, including the healthcare sector, must submit information from OSHA Form 300A. These businesses also have the same submission requirements for 2016 and 2017 as their larger counterparts. However, beginning in 2019, the submission deadline will be changed from July 1 to March 2 for the previous year (2018).

Timeliness of the data collected is critical in order to pinpoint and mitigate workplace hazards. Eliminating a hazard early on will help reduce the chances of another employee being injured or becoming ill.

Injury and illness data collected by OSHA under this new recordkeeping rule will be posted on the federal agency’s website. Any personally identifiable information (PII) will be removed before it is posted publicly.

The final rule also allows OSHA to collect information from employers that are not required to submit information to the agency on a routine basis. These employers would only be required to submit the data requested upon written notification from OSHA. States operating their own job safety and health programs must adopt requirements substantially identical to the requirements of the OSHA rule within six months after publication of the final rule.

Additionally, under the final rule, OSHA reemphasizes the requirements for whistleblower protections. Employers must inform employees of their right to report work-related injuries and illnesses free from retaliation. An employer’s procedures for reporting work-related injuries and illnesses must be reasonable and must not deter or discourage employees from reporting. Also, employers must not retaliate against employees for reporting work-related injuries or illnesses.

Employee safety is critical to having a productive, healthy organization. It is also a key component in helping to drive down Workers’ Compensation insurance costs. Manchester Specialty specializes in providing Workers’ Comp to the staffing industry and, together with Key Risk, also offers tailored risk management solutions designed to reduce Workers’ Compensation exposures, establish integrated safety action plans, and develop effective transitional workplace duty programs. The goal of our risk management services is to establish a safer workplace, experience fewer workplace injuries, and improve an organization’s experience modification factor – a primary component used in calculating Workers’ Compensation premiums.

For more information about our Workers’ Compensation insurance solutions and risk management services, you or your local agent/broker may contact us at 855.972.9399.