By Brent I. ClarkJames L. Curtis, Patrick D. Joyce, Adam R. Young, and Craig B. Simonsen

Seyfarth Synopsis:  Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in specific industries with historically high rates of occupational injuries and illnesses, are required to electronically submit their 300A forms to OSHA by March 2.

On January 7, 2020, OSHA posted a Tweet reminding employers subject to OSHA electronic reporting of injury and illness records that their OSHA 300A Annual Summary is due to be electronically filed by March 2, 2020.  As we have previously blogged, OSHA no longer requires employers to electronically file their full OSHA 300 Logs along with the OSHA 300A Annual Summary.

As we previously blogged in OSHA Has Begun Using Electronically Filed 300A Data to Target Specific Industries and Facilities, OSHA published the electronic reporting due dates in its Site-Specific Targeting 2016 (SST-16).

After receiving the 300A forms from employers, OSHA indicated that it “will target high injury rate establishments in both the manufacturing and non-manufacturing sectors for inspection.”  The agency will then perform comprehensive inspections of employers who are selected for Program. 

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Seyfarth Workplace Safety and Health (OSHA/MSHA) Team.