Atlanta Lawyer Weighs in on OSHA’s Proposed Rule Removing Electronic Reporting

Micah Dickie was interviewed by SHRM shortly after the Occupational Safety and Health Administration (OSHA) announced a proposed rule March 28 that would remove one electronic reporting requirement while adding others for high-hazard industries.

The proposed rule would update the classification system used to determine the list of industries covered by the electronic submission requirement; require establishments to include their company name when making electronic submissions to OSHA; remove the current requirement for establishments with 250 or more employees not in a designated industry to electronically submit information from their Form 300A to OSHA annually; and require establishments with 100 or more employees in certain high-hazard industries to electronically submit information from their OSHA Forms 300, 301 and 300A to OSHA once a year.

"Recordability of any injury on your 300 log is a serious matter," said Micah, when asked about the current OSHA record-keeping requirements.

While the OSHA 300 log doesn't currently have to be filed with OSHA, employers that have establishments with 250 or more employees and certain other smaller employers currently must electronically submit the 300A summary to OSHA in early March each year, he noted.

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