How OSHA’s New Injury Tracking Application Could Impact Your Business
By Mike Salazar —
Attention, employers! As of August 1st, OSHA is ready to receive electronic reports of your OSHA logs of injury and illness, with the new final deadline being December 1st of this year.
Employers who have 250+ employees in any one physical location/establishment that are currently required to keep OSHA injury and illness records and employers in certain industries with 20–249 employees in an establishment will now need to post their completed 2016 300A summary by December 1, 2017.
OSHA announced a two-year phase in time frame for all three forms (300A, 300 and 301) for covered establishments with 250+ employees. All three completed 2017 forms for must be posted by July 1, 2018 and by March 2 of each year thereafter.
Employers in certain industries with 20-249 employees in any one physical location/ establishment must post their 300A summary only by the new deadlines of July 1, 2018 and March 2 of each year thereafter.
These new posting requirements were passed during the Obama administration and are only now going into effect. Prior to the new rules, the Bureau of Labor Statistics would survey random companies to arrive at benchmark figures by industry and demographics. Unfortunately, the BLS and OSHA are not yet in sync and employers receiving the survey from the BLS are still required to report to them as well. OSHA and the BLS are working together to eliminate the double reporting for select employers. As of this writing the time frame to eliminate double reporting has not been announced.
Why the change? Based on the final rule, OSHA believes that electronic submission of this data will allow them to improve their ability to identify, target, and remove safety and health hazards to ultimately prevent workplace injuries and more.
The final rule doesn’t add or change an employer’s obligation to complete, retain, and certify injury and illness records. It’s just that there will now be two big differences:
- The records will be publicly available.
- The records must be submitted electronically and may not be submitted on paper.
The fact that your Illness & accident data will be “going public” has the potential to impact your business in three primary ways:
- Sales — It can affect sales because customers and potential customers will be able to easily review your employee injury and illness rates and those of your competitors. Customers may interpret high rates as an indication of poor service and delivery, or substandard product. Low rates could have the opposite impact.
- Staffing — The new rule can affect your ability to hire and retain staff because employees and applicants can easily review your incident rates and those of your competitors. Employees may prefer to work for “safer” employers.
- Insurance — The rule can affect your insurance cost for Workers Compensation because Underwriters may choose to quote your business based on the posted injury and illness rates. If fewer Underwriters opt to quote, your insurance cost will likely increase due to the reduced competition for your insurance business. and the reverse is also true. Conversely, employers with better rates may see in an increase in competition, driving down cost.
My advice to employers? Beware – and be accurate. Now more than ever it’s important to focus on safety to keep your OSHA rates low. Understand the rules of reporting and don’t under-report or over-report. You can review the reporting rules in regulation 29 CFR, Part 1904.