Those reports are submitted electronically using Form 300A.1 The deadline to submit that form is March 2, 2019. In other words…it is very rapidly approaching. As OSHA (the agency) recently announced:
March 2, 2019, is the deadline for electronically reporting your OSHA Form 300A data for calendar year 2018. Collection will begin January 2, 2019.
OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule.
Remember, not all establishments are covered by this requirement. Review which establishments need to provide their data.
OSHA also has a tutorial to help reporting businesses. The failure to report as required can expose the applicable businesses to substantial penalties.2
A note from first-hand experience: OSHA inspects workplaces from time-to-time, and certainly following jobsite related injuries. In the course of their investigations OSHA’s inspectors will ask for copies of a company’s Forms 300, 300A, and others as-required. A company’s HRM (Human Resource Manager; this writer has performed that function, and is actually a member of the Society for Human Resource Management) should have ready access to those documents at all times. “Consider yourselves duly noticed…”
1 https://www.osha.gov/injuryreporting/index.html
2 https://www.ehstoday.com/safety/osha-cracks-down-failure-file-electronic-injury-reports
3 https://www.boginmunns.com/two-2019-state-local-tax-matters-florida-businesses/
– For more information, call Philip N. Kabler of the Gainesville, FL office of Bogin, Munns & Munns at 352.332.7688, where he practices in the areas of business, banking, real estate, and equine law. He has taught business and real estate law courses at the University of Florida Levin College of Law and Warrington College of Business Administration. And is now the President-Elect of the Eighth Judicial Circuit Bar Association.
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NOTICE: The article above is not intended to serve as legal advice, and you should not rely on it as such. It is offered only as general information. You should consult with a duly licensed attorney regarding your Florida legal matter, as every situation is unique. Please know that merely reading this article, subscribing to this blog, or otherwise contacting Bogin, Munns & Munns does not establish an attorney-client relationship with our firm. Should you seek legal representation from Bogin, Munns & Munns, any such representation must first be agreed to by the firm and confirmed in a written agreement.
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