Get the Record Straight: OSHA's New Injury Recordkeeping E-Submission Rule

Duration: 120 Minutes
Attending this webinar by expert speaker Joe Keenan will give you a clear understanding of your responsibility for the new electronic submittal process and ramifications to the employer.The U.S. Occupational Safety and Health Administration (OSHA) has changed elements of the 29 Code of Federal Regulation (CFR) 1904 to include electronic submittal of injury and illness data. OSHA believes this is a behavioral economic move to provide a "nudge" to employer to focus on safety. The information for injury and illness will be available publicly and is believed to help accuracy of recordkeeping data.
29 CFR 1904
Instructor: Joe Keenan
Product ID: 509804
This rule will be phased into effect within a two-year period with certain high-risk employers being targeted for more frequent reporting than their low-risk counterparts. Whereas, employers with high injury rates will have injury records available for workers, job seekers, customers, researchers, and the general public that will affect the way they do business.

Objectives of the Presentation
Attend the session to know the answers to:
  • What does the final rule do?
  • How will the rule benefit workers?
  • Why is OSHA collecting the data and how will it be used?
  • Does the rule require employers to start keeping new records or change how the keep the records?
  • Why does OSHA address retaliation in this rule? Isn't already against the law to retaliate against an employee for reporting a workplace injury or illness?
  • How should an employer inform employees of their right to report work-related injuries and illness free from retaliation by their employer?
  • May an employer require post-incident drug testing for an employee who reports a workplace injury or illness?
  • Does the rule allow and employer to have an employee incentive program?
  • Does this rule apply to employers in State Plan states?
  • How can employers use this information to improve their own safety record?
  • Who must submit information electronically to OSHA under the final rule?
  • Are the electronic reporting requirements based on the size of the establishment or the size of the firm?
  • When do I have to submit data electronically to OSHA?
  • How should the data be submitted and how long will it take?
  • How will Personally Identifiable Information (PII) be protected?
Why Should you Attend
OSHA has been rushing out a series of proposed amendments to its Injury & Illness Recordkeeping regulations (29 C.F.R. Part 1904). Among them is a new final rule to "Improve Tracking of Workplace Injuries and Illnesses," which will require hundreds of thousands of employers to electronically submit their injury and illness logs (and in many instances, their detailed incident reports also) each year. More importantly, for no apparent safety reason, OSHA intends to publish employers' injury data and incident reports online.

Another rule working its way through the rulemaking process: "Continuing Duty to Maintain Up-to-Date and Accurate Injury & Illness Records," would impose a continuing duty on employers to update and maintain accurate injury and illness logs for the entire five year period for which the current regulation requires employers to keep copies of their OSHA 300 logs and related forms. Essentially, this proposal extends OSHA's statute of limitations period during which OSHA is allowed to bring an enforcement action alleging a violation of the recordkeeping standard from six months from the day of the recordable injury to five years.

Participants will learn:
  • Details of OSHA's new final rule to require submission of injury and illness recordkeeping data
  • Requirements of OSHA's proposed rule to extend its recordkeeping statute of limitations
  • Potential impact of these two recordkeeping rules
  • Timing for implementation of both rules
Areas Covered
  • Understanding the new requirements for electronic injury and illness reporting
  • How to correctly fill out the OSHA 300, 301, and 300A logs
  • Understanding the compliance scheduling for all industries
  • Determining if you are a high-risk industry
  • Possible outcomes to this rule to business and industries
  • Tips for complying with all of 29 CFR 1904
  • 29 CFR 1904 review for the most cited violations of the standard
  • Compliance scheduling for the new rule
  • Detail review of the new rules
  • Tips for lowering Total Recordable Injury Rates (TRIR) and Days Away Restricted Transfer (DART) rates
  • A resource guidance for the standard
Who will Benefit
This webinar will be beneficial for:
  • CEO or Company Executive
  • Compliance & Safety Officer
  • Director of Risk Management
  • Director of Human Resources
  • Regulatory Compliance Agent
  • Risk Advisor-Insurance Companies
  • General Contractors
  • Process Technicians
  • Warehouse Managers
  • General Employees
  • Oil and Gas, Agriculture, Utilities
  • Construction Contractors, Nurses, Physicians
  • HR Managers, Safety Managers, Facility Managers
  • In-house Attorneys, Risk Managers, Business Owners
Topic Background
The new rule, which takes effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms.

The new reporting requirements will be phased in over two years:

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.
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Instructor Profile:
Joe Keenan is a highly experienced Environmental Health and Safety (EHS) and human resources professional and management consultant with over 21 years of experience. He received his Six Sigma/Lean Manufacturing Green Belt in 2005, MBA with a human resource management concentration in 2007 and Certified Safety Professional (CSP) in 2011. He currently serves as President of the Mississippi Chapter of the American Society of Safety Engineers (ASSE). Mr. Keenan has served on the OSHA Voluntary Protection Program Participants Association (VPPPA) Region IV Board of Directors as a Director at Large from 2013-2015. Since 2002, he is an OSHA General Industry and Construction 10/30-Hour Authorized Outreach Trainer.
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