OSHA Has a “Naughty” List – And Nearly One-Third of Large Employers Are on It. Are You?

OSHA (the Occupational Safety and Health Administration) issued its electronic injury reporting rule in May, 2016.  When issued, OSHA had intended all employers (over time) to submit their injury and illness records (OSHA Form 300 log of work-related injuries and illnesses), OSHA Form 301 (injury and illness incident report), and OSHA 300A (annual summary of work-related injuries and illnesses by establishment)) via a “secure” electronic system.  OSHA would then use this information to publicly shame employers who had high injury or illness rates.  The initial electronic filing obligation was limited to employers with 250 or more employees and employers with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.  The initial filing was limited to the OSHA Form 300A, with a filing due date of July 1, 2017; which was then later moved back to December 30, 2017. In the lead up…

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