Authored by Don Lawless, Mark Kittaka and Patricia Ogden Last week, the federal Occupational Safety and Health Administration (OSHA) announced that it “is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date by which certain employers are required to submit the information from their completed 2016 Form 300A electronically.” No additional detail or explanation was provided. OSHA states that additional updates will be posted to the agency’s recordkeeping website when they become publicly available. The rule requires certain employers to electronically submit injury and illness data to OSHA. The agency intends to analyze the data for enforcement purposes and post some of it publicly (naming employers) to its website. Establishments with 250 or more employees in industries covered by the recordkeeping regulation faced the now postponed July 1 deadline. Establishments with 20-249 employees in certain high-risk industries faced the July 1 deadline also. The 22 states or territories with their own occupational safety and health programs generally are using the federal OSHA electronic submission platform and similarly will be delayed. Litigation brought by the National Association of Home Builders and the U.S. Chamber of Commerce challenging this aspect of the recordkeeping rules continues in the federal trial court in the Western District of Oklahoma. This postponement does not impact the other aspects of the new recordkeeping rule including its anti-retaliation provisions, employer injury reporting, and worker notice requirements.
RELATED ARTICLES
Supreme Court Blocks OSHA Vaccine-or-Test Mandate
January 13, 2022 | Currents - Employment Law, Employee Health Issues, Supreme Court Watch
Future of OSHA Vaccine-or-Test Mandate Looks Tenuous as Supreme Court Weighs In
January 7, 2022 | Currents - Employment Law, Employee Health Issues, Supreme Court Watch
OSHA’s COVID-19 Vaccine, Testing Mandates Back On – Effective Jan. 10, 2022
December 20, 2021 | Currents - Employment Law, Employee Health Issues
Courts Enjoin Federal COVID-19 Vaccine Mandates – An Update
December 9, 2021 | Currents - Employment Law, Employee Health Issues
Biden Administration’s COVID-19 Vaccine Initiative: Preparation. Not Panic.
September 17, 2021 | Currents - Employment Law, Employee Health Issues
Supreme Court Blocks OSHA Vaccine-or-Test Mandate
January 13, 2022 | Currents - Employment Law, Employee Health Issues, Supreme Court Watch
Future of OSHA Vaccine-or-Test Mandate Looks Tenuous as Supreme Court Weighs In
January 7, 2022 | Currents - Employment Law, Employee Health Issues, Supreme Court Watch
OSHA’s COVID-19 Vaccine, Testing Mandates Back On – Effective Jan. 10, 2022
December 20, 2021 | Currents - Employment Law, Employee Health Issues
Courts Enjoin Federal COVID-19 Vaccine Mandates – An Update
December 9, 2021 | Currents - Employment Law, Employee Health Issues
Biden Administration’s COVID-19 Vaccine Initiative: Preparation. Not Panic.
September 17, 2021 | Currents - Employment Law, Employee Health Issues
Biden pushes OSHA and employers along his ‘path out of the pandemic’
September 13, 2021 | Currents - Employment Law, Labor Relations
Masks Off to the Fully Vaccinated: COVID-19 Safety in the Health Care Workplace
July 1, 2021 | Currents - Employment Law, Employee Health Issues
MIOSHA Amends COVID-19 Emergency Rules
May 24, 2021 | Currents - Employment Law, Employee Health Issues
Court Won’t Step in For OSHA in Pandemic-Plagued Meat Packing Plant
April 8, 2021 | Currents - Employment Law, Employee Health Issues
Government Report Calls On OSHA To Step Up Its Response to COVID-19
March 8, 2021 | Currents - Employment Law, Employee Health Issues
Use Your Noodle: Assistant Manager Sues Over COVID-19 Related Termination
September 11, 2020 | Currents - Employment Law
Employers Need Not Tolerate HR Professionals Who Encourage Coworkers to File Discrimination Suits
July 31, 2020 | Currents - Employment Law, Employment Discrimination
Can Employees Participate in Protests During Their Workday?
July 20, 2020 | Currents - Employment Law
Reopening in Indiana—The Governor Says You’ll Need A Safety Plan
May 5, 2020 | Currents - Employment Law, Employee Health Issues
Third-Party Biometric Timekeeping Provider Chops Down BIPA Liability
April 14, 2020 | Currents - Employment Law
Los Angeles Will Require COVID-19-Related Paid Sick Leave for Large Employers
March 31, 2020 | Currents - Employment Law, Employee Health Issues, Employee Leave
How Do You Complete or Update I-9s When Your Company is Remote?
March 25, 2020 | Currents - Employment Law
Are COVID-19 Claims Compensable Under Indiana’s Occupational Disease Act?
March 23, 2020 | Currents - Employment Law, Employee Health Issues
California Offers Relief from State WARN Act Requirements
March 18, 2020 | Currents - Employment Law
Illinois Supreme Court BIPA Ruling Triggers Risks for Private Employers
February 1, 2019 | Currents - Employment Law, Social Media and Technology
Sixth Circuit Holds Full-Time Presence at Work not Essential Simply Because an Employer Says So
July 20, 2018 | Employment Discrimination, Pregnancy, Currents - Employment Law
E is for Equal Pay: Pay Data Reporting And The Shifting Meaning Of “Equal Work”
July 5, 2018 | Letter of the Law, Currents - Employment Law
D is for Drugs: Employee Drug Use and What You Should Know
June 26, 2018 | Letter of the Law, Currents - Employment Law
Letter C: Co-Workers With Criminal Records? Your Workforce May Be More Open-Minded Than You Think
May 24, 2018 | Letter of the Law, Currents - Employment Law
California Supreme Court Ruling to Give More Workers Employee Status
May 2, 2018 | Employment Lessons, Currents - Employment Law
B is for “Bias” - Is Bias The Not-So-New Cause of Discrimination?
April 24, 2018 | Employment Lessons, Letter of the Law, Currents - Employment Law
Employers, You Can Do This
April 23, 2018 | Employment Lessons, Currents - Employment Law
Medical Marijuana is Coming to Ohio– What Employers Need to Know
March 23, 2018 | Employment Lessons, Currents - Employment Law
What’s Old Is New Again: DOL Resurrects Advisory Opinion Letters
January 16, 2018 | Employment Lessons, Fair Labor Standards Act, Currents - Employment Law
Employment Visas: Changes to Expect in 2018
December 20, 2017 | Employment Lessons, High Stakes Employment Issues, Currents - Employment Law
OSHA Extends Electronic Recordkeeping Submission Deadline to Dec. 15
November 28, 2017 | Employment Discrimination, Employment Lessons, Currents - Employment Law
Get a Room! Rethink Conducting Employee Reviews Over Lunch
August 25, 2017 | Employment Lessons, Currents - Employment Law
Trump-Era Immigration Worksite Raid Threats May Bring New Requirements for California Employers
June 2, 2017 | Employment Lessons, Currents - Employment Law
Six Statements That May Mean Your Business Will Keep an Employment Lawyer Busy
June 1, 2017 | Employment Lessons, Currents - Employment Law
Hiring Teenagers This Summer? Here are 3 Key Considerations
May 17, 2017 | EEOC, Employment Discrimination, Currents - Employment Law
Trump’s Actual Impact on OSHA
May 12, 2017 | Employment Lessons, Currents - Employment Law
House Passes Bill to Legalize Comp Time in the Private Sector
May 8, 2017 | Fair Labor Standards Act, Currents - Employment Law
Lessons Learned: Job Descriptions Do Matter
May 1, 2017 | Employment Discrimination, Employment Lessons, Currents - Employment Law
Your Questions About Ohio’s New Gun Law Answered
April 4, 2017 | Employment Lessons, Currents - Employment Law
Paid Leave American-Style: “I Get Mine, But You Can’t Have Yours!”
March 31, 2017 | Employee Leave, Currents - Employment Law
Easy Come, Easy Go: Appeals Court Reverses $2.6 Million Award in ADA Case
March 24, 2017 | Employment Lessons, Currents - Employment Law
Mugshots Gone Viral: Internet Clickbait is a Hiring Manager’s Minefield
March 16, 2017 | Employment Discrimination, Currents - Employment Law
Unwise Old Sayings? Watch Out For Stereotypes That Might Trigger An Age Discrimination Lawsuit
March 9, 2017 | Employment Discrimination, Currents - Employment Law
Hotel California Checks Out of State Forum Selection Clauses
February 13, 2017 | Employment Lessons, Currents - Employment Law
2016: EEOC Charges Keep Climbing
February 8, 2017 | EEOC, Currents - Employment Law
EEOC’s Latest Guidance On Mental Health Accommodations Adds Little
January 31, 2017 | EEOC, Currents - Employment Law
Survey Says: About Half of Employers Offering Paid Sick Leave
January 30, 2017 | Employment Lessons, Currents - Employment Law
Drill Deeper Than “Fit” as Reason For Termination
January 26, 2017 | Employment Lessons, Currents - Employment Law
OSHA Issues Enforcement Guidance on Controversial Non-Discrimination Provisions
January 9, 2017 | Employment Discrimination, Currents - Employment Law
Ohio Employers May Soon See Employees Packing Heat in Their Cars
December 15, 2016 | Employment Lessons, Currents - Employment Law
OSHA Contemplates Workplace Violence Standard for Healthcare, Social Assistance Workers
December 8, 2016 | Employment Lessons, Currents - Employment Law
The World According to Trump: Trump’s Potential Impact on OSHA
November 29, 2016 | Employment Lessons, Currents - Employment Law
Cook County, Illinois, Approves Increased Minimum Wage for Suburban Workers Beginning Next Year
October 28, 2016 | Employment Lessons, Currents - Employment Law
UPDATE: OSHA Announces Second Delay in Enforcement of Non-Discrimination Provisions
October 24, 2016 | Employment Lessons, Currents - Employment Law
OSHA Announces Delay in Non-Discrimination Provisions, Higher Fines Still Coming in August
July 21, 2016 | Employment Discrimination, Currents - Employment Law
OSHA’s New Mandatory Electronic Recordkeeping Rule
June 23, 2016 | Employment Discrimination, Currents - Employment Law
DOJ Announces that Criminal OSHA Prosecutions May Also Include Felony Environmental Crimes
December 22, 2015 | High Stakes Employment Issues, Currents - Employment Law
OSHA FINES COULD INCREASE OVER 80% NEXT YEAR
November 10, 2015 | High Stakes Employment Issues, Currents - Employment Law
Nearly 40 Percent of Mandatory Reports to OSHA Lead to Inspection
October 5, 2015 | Employee Health Issues, Currents - Employment Law
Transgender Status in the Workplace – First an EEOC Issue and Now an OSHA Issue?
May 28, 2015 | EEOC, Employment Discrimination, Currents - Employment Law
Supervisors Are Employees Too … to the Tune of $6.6 Million
April 29, 2015 | Employment Discrimination, High Stakes Employment Issues, Currents - Employment Law
Signing Section 2 of I-9 Forms Can Get You in Trouble!
February 12, 2015 | Employment Lessons, Currents - Employment Law
The Employer Mandate Is Almost Here. Is Your Company Ready?
December 5, 2014 | Employee Health Issues, Currents - Employment Law
Ebola – How Should Employers Respond?
November 4, 2014 | Employee Health Issues, Currents - Employment Law
OSHA ISSUES NEW MANDATORY REPORTING REQUIREMENTS FOR SERIOUS INJURIES; DATA TO BE MADE PUBLIC
September 18, 2014 | Employee Health Issues, Currents - Employment Law
OSHA-Proposed Mandatory Reporting Rule Could Include Enterprise-Wide Reporting
January 13, 2014 | Employee Health Issues, Currents - Employment Law
OSHA’s New Online Complaint Form May Increase Whistleblower Investigations
December 16, 2013 | Social Media and Technology, Currents - Employment Law
OSHA Develops Plan to Publish Injury and Illness Data Online
November 12, 2013 | Employee Health Issues, Social Media and Technology, Currents - Employment Law
OSHA’S Revised Hazard Communications Standard Imposes New Training Requirements by Dec. 1, 2013
June 18, 2013 | Traditional Labor, Currents - Employment Law
OSHA Interpretation Letter Allows Non-Union Employees to Designate Union Personnel as “Representative” During OSHA Inspection
April 30, 2013 | Traditional Labor, Currents - Employment Law
OSHA – Regulatory and Enforcement Update
February 11, 2013 | Employment Discrimination, Currents - Employment Law
OSHA - Employers have a duty to help prevent heat-related illnesses
July 13, 2012 | Employee Health Issues, Currents - Employment Law
RELATED PRACTICE AREAS
Subscribe
Do you want to receive more valuable insights directly in your inbox? Visit our subscription center and let us know what you're interested in learning more about.
View Subscription Center