OSHA Delays Electronic Recordkeeping Deadline but Concerns Abound

As many people already know, OSHA has delayed the electronic recordkeeping requirement; they have changed it from 1 July 2017 to 1 December 2017.  In addition, OSHA is soliciting comments on other provisions of this rule.  For those brave souls that would like to wade through some bureacratese, you can find the full-text of this announcement in the Federal Register here.

This is welcome news but it is unclear if other changes will occur.  Both under-recording and over-recording each have their problems under this new rule – The accurate management of OSHA-recordable cases, while always important, takes on even more significance now.

While we wait for OSHA to figure things out, let’s look at a few details of this rule and find out what it requires.

Quoting from OSHA:

“Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2…Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2. OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.”

https://www.osha.gov/recordkeeping/finalrule/index.html.  Accessed 14 July 2017.

We must wait to find out if there are any new developments on this rule.  In the meantime, take some time to review your OSHA logs, make sure they are current and that you have not made any over-recording or under-recording errors.

By the way, high-risk industries are defined as those industries that fall under designated NAICS codes as defined by OSHA.  This includes construction, manufacturing and many other industries.  Here is that list…

  •  11    Agriculture, forestry, fishing and hunting
  •  22    Utilities
  •  23    Construction
  •  31-33   Manufacturing
  •  42        Wholesale trade
  •  4413    Automotive parts, accessories, and tire stores
  •  4421    Furniture stores
  •  4422    Home furnishings stores
  •  4441    Building material and supplies dealers
  •  4442    Lawn and garden equipment and supplies stores
  •  4451    Grocery stores
  •  4452    Specialty food stores
  •  4521    Department stores
  •  4529    Other general merchandise stores
  •  4533    Used merchandise stores
  •  4542    Vending machine operators
  •  4543    Direct selling establishments
  •  4811    Scheduled air transportation
  •  4841    General freight trucking
  •  4842    Specialized freight trucking
  •  4851    Urban transit systems
  •  4852    Interurban and rural bus transportation
  •  4853    Taxi and limousine service
  •  4854    School and employee bus transportation
  •  4855    Charter bus industry
  •  4859    Other transit and ground passenger transportation
  •  4871    Scenic and sightseeing transportation, land
  •  4881    Support activities for air transportation
  •  4882    Support activities for rail transportation
  •  4883    Support activities for water transportation
  •  4884    Support activities for road transportation
  •  4889    Other support activities for transportation
  •  4911    Postal service
  •  4921    Couriers and express delivery services
  •  4922    Local messengers and local delivery
  •  4931    Warehousing and storage
  •  5152    Cable and other subscription programming
  •  5311    Lessors of real estate
  •  5321    Automotive equipment rental and leasing
  •  5322    Consumer goods rental
  •  5323    General rental centers
  •  5617    Services to buildings and dwellings
  •  5621    Waste collection
  •  5622    Waste treatment and disposal
  •  5629    Remediation and other waste management services
  •  6219    Other ambulatory health care services
  •  6221    General medical and surgical hospitals
  •  6222    Psychiatric and substance abuse hospitals
  •  6223    Specialty (except psychiatric and substance abuse) hospitals
  •  6231    Nursing care facilities
  •  6232    Residential mental health and substance abuse facilities
  •  6233    Community care facilities for the elderly
  •  6239    Other residential care facilities
  •  6242    Community food, housing and emergency and other relief services
  •  6243    Vocational rehabilitation services
  •  7111    Performing arts companies
  •  7112    Spectator sports
  •  7121    Museums, historical sites, and similar institutions
  •  7131    Amusement parks and arcades
  •  7132    Gambling industries
  •  7211    Traveler accommodation
  •  7212    RV (recreational vehicle) parks and recreational camps
  •  7213    Rooming and boarding houses
  •  7223    Special food services
  •  8113    Commercial and industrial machinery and equipment (except automotive and electronic) repair and maintenance
  • 8123    Dry-cleaning and laundry services

Join us 17 August 2017 from 0830 to 1100 for a free OSHA-record-keeping seminar.  

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