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L&I to Implement new Electronic OSHA 300 Recordkeeping Reporting Rules
January 6, 2020
New Rule Highlights: WAC 296-27-03103

 

What does the new DOSH rule do?
The new changes to DOSH’s rule are required in order to be at least as effective as OSHA.

Requires certain employers (depending on size and industry type) to annually submit electronic injury and illness records to federal OSHA that they are already required to keep under the recordkeeping regulations.

Who must submit information electronically to OSHA under the new rule?
Establishments with 250 or more employees that are already required to keep OSHA Form 300 logs must electronically submit to OSHA information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A).

Establishments with 20-249 employees and in certain high-risk industries must electronically submit to OSHA information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A). Only those establishments that meet BOTH criteria must electronically submit their records annually.

Establishments with fewer than 20 employees at all times during the year (or who are normally exempt by size or industry) will only need to electronically submit records to Federal OSHA “Upon written notification” from Federal OSHA. This group must follow the instructions in the written notification.

Does the rule require employers to start keeping new records or change how they keep records?
No. The new requirement does not add to or change an employer's obligation to complete, retain, and certify injury and illness records. It only requires certain employers to electronically submit some of the information from these records to OSHA.

How do I determine my correct employee count?
Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.

When do I have to submit data electronically to OSHA?
Employers must submit information from OSHA Forms 300A by March 2, 2020.

Do I still need to post my OSHA 300A summary from February 1st to April 30th as usual?
Yes.

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