FEDERAL OSHA IS REQUIRING AFFECTED EMPLOYERS IN COVERED STATE PLANS TO SUBMIT THEIR DATA ELECTRONICALLY BY JULY 1, 2018
Log 300 Recording and Reporting Occupational Injuries and Illnesses, with Anti-Discrimination Provisions
Effective January 1, 2017, employers in states regulated by federal OSHA were required to electronically submit Log 300 records of injuries and illnesses. The electronic reporting requirements, along with the incorporation of an existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses, were added to federal OSHA's recording and reporting regulations found in the Code of Federal Regulations, title 29, part 1904.
On April 30, 2018, federal OSHA posted a "trade release" requiring all affected employers to submit injury and illness data in the federal OSHA Injury Tracking Application (ITA) online portal, even if the employer is covered by a state plan that has not completed the adoption of their own state rule: https://www.osha.gov/news/newsreleases/trade/04302018.
Therefore, even though California has not yet adopted its own state rule, affected employers are advised to comply with federal OSHA's directive to provide Form 300A data covering the calendar year 2017. Federal OSHA is requiring affected employers to submit their data by July 1, 2018. For specific instructions, go to federal OSHA's ITA website: https://www.osha.gov/injuryreporting/index.html.
Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to send their information. Remember, these criteria apply at the establishment level, not to the firm as a whole.
The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
The establishment's industry is on this list (https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html), regardless of the size of the establishment.
The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is not on this list (https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.html).