In May 2016, the federal Occupational Safety and Health Administration ("OSHA") adopted new requirements for recording and submitting records of workplace injuries and illnesses. For decades, employers have tracked employee injuries and illnesses on an "OSHA Log." Historically, employers in California have maintained the OSHA logs at their establishment and retained these records for five (5) years. With some exceptions, the recorded information was not reported to Cal/OSHA but that will soon change.
Effective January 1, 2017, certain employers were required to submit the records of workplace injuries and illnesses to OSHA electronically for posting on the OSHA website to "help keep workers safer and make employers, the public, and government better informed about workplace hazards." Initially, the new requirements did not apply to states which had their own State Plan. However, OSHA recently notified State Plans that for Calendar Year 2017 all employers covered by State Plans will be expected to comply. An employer covered by a State Plan that has not completed adoption of a state rule must provide Form 300A data for Calendar Year 2017 in compliance with the new rules. Employers are required to submit their data by July 1, 2018. There will be no retroactive requirement for employers covered by State Plans that have not adopted a state rule to submit data for Calendar Year 2016.
California employers must comply with the new electronic submission requirements for the OSHA 300A forms on or before July 1, 2018.