Have you been submitting your 300A online? 

OSHA has required online submission of the 300A for a few years, and now they’re going to start ensuring companies have been submitting them during inspections.

What does the rule require?
The new rule, which went into effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. Analysis of this data will enable OSHA to use its enforcement and compliance assistance resources more efficiently. Some of the data will also be posted to the OSHA website. OSHA believes that public disclosure will encourage employers to improve workplace safety and provide valuable information to workers, job seekers, customers, researchers and the general public.

Compliance schedule
The new reporting requirements:
•         Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2021 Form 300A by March 2, 2022.

•         Establishments with 20-249 employees in certain high-risk industries must submit information from their 2021 Form 300A by March 2, 2022.

https://www.osha.gov/injuryreporting/ 

New Enforcement 
OSHA has set enforcement guidance regarding potential violations of the Occupational Safety and Health Administration’s (OSHA) rule requiring electronic submittal of injury and illness records, 29 CFR 1904.41(a)(1) and (a)(2).

Each Area Office has access to the Injury Tracking Application (ITA) database containing each Form 300A submitted to OSHA. Compliance safety and health officers (CSHOs) should refer to this database during all inspections to identify employers that were required to submit records1 but failed to do so. Employers shall not be cited for failure to submit records by March 2, provided the employer attempted to submit its records but was unable to do so due to performance problems associated with the ITA. The data must have been submitted, however, in a timely fashion once the ITA becomes operational. Area Directors may direct CSHOs to perform a full recordkeeping audit where there is evidence of potential systemic recordkeeping issues.

OSHA Form 300A data for the preceding calendar year must be electronically submitted to OSHA each year by March 2 of the following year. The six month date to issue a citation for non-compliance with the requirements of 29 CFR 1904.41 will therefore be September 2. As an example, data for calendar year 2020 must be submitted to OSHA by March 2, 2021. OSHA may issue a citation for failure to submit up until September 2, 2021.

You can read a memo with additional enforcement guidance here.