OSHA Reporting Deadline – Update

You may recall our recent blog post on OSHA’s new online reporting requirements. Last Friday, December 15th, had been the cut-off date for submitting your information. On Monday December 18th OSHA issued a press release indicating they would continue to accept electronic reporting of the mandatory information until midnight on December 31, 2017. OSHA will not take action against employers who submit their logs between now and the 31st. However, effective January 1, 2018 you will no longer be able to submit your 2016 data.

Working with various clients over the past few days, a few questions consistently came up among several:

What is an establishment?
For recordkeeping purposes OSHA defines an establishment as “a single physical location where business is conducted or where services or industrial operations are performed” for one year or longer. For online recording, this establishment is also required to exceed 20 employees at some point in the reporting year. You will need to report your required information for EACH INDIVIUAL ESTABLISHMENT.

If the establishment is fewer than 20 employees AT ALL TIMES during the year, do I need to submit my information online?
No. However, you continue to keep a log for any facility that is in operations for longer than 1 year.

What if I am part of a state OSHA program?
To further complicate matters, OSHA approved state plans have not yet adopted the requirements. It is our understanding the state plans will adopt the requirements within 6 months of publication of the final rule.

Where do I create an account and submit my data?
On the Injury Tracking Application Page.

As always, if you have any questions regarding this information please reach out to the J.W. Terrill Loss Control department at losscontrol@jwterrill.com.

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About John Flynn

Prior to joining J.W. Terrill, Inc., John worked in construction as a safety manager for a General Contractor in the St. Louis area. In this role, he was responsible for implementing new safety policies and procedures, as well as traveling across the U.S. visiting various jobsites on a bi – weekly basis. Prior to working in construction, John worked 3 years for a nationwide cleaning service handling worker’s compensation and liability claims as well as accident investigations. John joined J.W. Terrill in September of 2014; he continues his efforts to serve clients by developing a detailed understanding of their business operations and helping to control possible exposures. This can take the form of sample programs, training, managing carrier loss control involvement, and identification of potential exposures with corresponding control options. John is a graduate of the University of Central Missouri (UCM) with a Bachelor’s degree in Safety Management and a minor in business administration. John is a member of the American Society of Safety Engineers (ASSE) and sits on the Associated General Contractors (AGC) safety committee. He is also an authorized OSHA outreach trainer for construction and a licensed producer in the state of Missouri for property and casualty insurance. John holds the Certified Safety Professional (CSP) designation from the board of Certified Safety Professionals.

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