Electronic Submission of Injury and Illness Records to OSHA

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The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA)  has extended the date by which certain employers must electronically report injury and illness data through the Injury Tracking Application (ITA) to December 15, 2017.

Who

Establishments with 250 or more employees who are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees which are classified in certain industries with historically high rates of occupational injuries and illnesses.

Exceptions

The following OSHA-approved State Plans have NOT yet adopted the requirement to submit injury and illness reports electronically: CALIFORNIA, MD, MN, SC, UT, WA and WY. Establishments in these states are not currently required to submit their summary data through the ITA.

ACTION ITEM:
Determine if you have locations in other States who must report through ITA.

Contact information for State Plans

Although California establishments currently do not have to submit their summary data electronically, you will still need to maintain your OSHA Logs as required.  The California recordkeeping standard applies to most employers having over ten (10) employees.

Recordkeeping Forms and Regulations

ACTION ITEM:
Determine if you are a partially exempt industry from having to comply with the recordkeeping requirements.

Partially exempt industries in California can be determined 2 ways:

1. The partial industry classification exemption applies only to establishments in the retail, services, finance, insurance, and real estate industries. The partial industry classification exemption is based on the industry classification of the individual establishments operated by your company.  If you operate several establishments engaged in different classes of activities, some of your company's establishments may be required to keep records, while others may be partially exempt.

List of Partially Exempt Industries, sorted by the first 4-digits of your company’s NAICS

As you can see by reading the content before this table (b)(2)(iii), the correct NAICS for Cal-OSHA is the 2002 version, even though there are 3 more updated versions available.

You can obtain your 2002 NAICS by either:

- Using the search feature by reviewing the 2002 NAICS industry listing
- Contacting your nearest Cal-OSHA Office

2. The partial exemption for size is based on the number of employees in the entire company.  Determine your company's peak employment during the last calendar year. If you had no more than 10 employees at any time in the last calendar year, your company qualifies for the exemption.

Note:   The exemptions do not apply if an employer is asked in writing to maintain injury and illness records by OSHA, the Bureau of Labor Statistics (BLS), a BLS designee, or a state agency operating under the authority of OSHA or the BLS.

 

IF YOU HAVE FURTHER QUESTIONS, PLEASE CONTACT:      

JEFF HULSON
Director, Risk & Loss Advisors
Phone: (858) 550-4987
jeff.hulson@MarshMMA.com