Your Privacy Matters, and OSHA Agrees.
For those of us who employ 250 or more employees, you are no longer required to electronically report injury and illness data from OSHA Forms 300 and 301 (you are still required to report data Form 300A). For a highlight of the Final Rule continue reading on, but for a full synopsis of Final Rule RIN 1218-AD17 click HERE.
While the Final Rule does away with some requirements, it does add some of its own. Employers must now add their Employer Identification Number (EIN) electronically along with data from Form 300A. While the requirement will become effective February 2, 2019, compliance for this provision will take place on March 2, 2020 (for data collected from year 2019). Keep in mind, the data from Form 300A still must be submitted to OSHA before March 2, 2019 for fiscal year 2018.
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Whatâ€™s Still Required
Although OSHA has deemed your personal information a top priority, this does not change an employerâ€™s obligation to complete and retain injury and illness records under OSHAâ€™s regulations for recording and reporting occupational injuries and illness. It also does not add or change any recording criteria or definitions of said records.
Simply put, OSHA did what OSHA does all the time. It weighed the economical and potential risks versus the benefits of storing large amounts of personal and sensitive information. In the end, OSHA found that there was no concrete evidence that it would in fact lead to better recording and reporting. For OSHA, the security risk was too great. Itâ€™s not a total loss though, OSHA did find that including the employers EIN will streamline reporting for employers who must report to both OSHA and BLS. It will improve the agenciesâ€™ ability to match their data along with improving the quality and utility of the collected data.