New Cal/OSHA 300 Log Electronic Reporting Requirements

In May 2016, The Occupational Safety and Health Administration (OSHA) released a Final Rule(1) for the electronic reporting of OSHA 300 logs beginning January 1, 2017.  As a State sponsored plan under Fed OSHA, Cal-OSHA”…must adopt requirements that are substantially identical to the Final Rule within 6 months after publication of the final rule”. (https://www.osha.gov/recordkeeping/final rule/index.html)

What does that mean for you? As a Participant of ALPHA Fund, below you will find several frequently asked questions and answers to guide you through these changes.

 

Q: When do the changes take effect?

A: While Cal-OSHA has not yet provided a ruling on how it will enforce this Final Rule, we know that the requirements will be at minimum, inclusive of all OSHA requirements.  The following are highlights that may apply to your organization as listed in the Final Rule.

Establishments with 250 or more employees

  • Employers currently required to keep OSHA 300 forms must submit form 300A electronically starting January 2017. Such employers will have until July 1, 2017 to submit Calendar year 2016 data.
  • Electronic filing of forms 300 and 301 will be phased in beginning in 2018 and employers will have until July 1, 2018 to submit calendar year 2017 data.
  • Beginning in 2019, all electronic filings must be completed by March 2nd.

 

Establishments with 20-249 employees in Certain Industries (2)

  • Employers currently required to keep OSHA 300 forms must submit form 300A electronically starting January 2017. Such employers will have until July 1, 2017 to submit Calendar year 2016 data.
  • Electronic filing of form 300A for 2017 data is required by July 1, 2018.
  • Beginning in 2019, all electronic filings must be completed by March 2nd.

 

Q: Is my employer’s NAICS code listed under the “certain Industries” (2) category?

A:  If you are employed by a current Participant organization in ALPHA Fund your organization is most likely to be on the Certain Industries classification list.  The industries on this list are statistically more hazardous than industries not on this list.  A full list of NAICS codes on this list can be viewed here.

Q: Does ALPHA Fund complete this form for me?

A: ALPHA Fund does not have the entirety of the data necessary to complete form 300A, 300 or 301 on your behalf.  If you have questions specific to what is required on this form, please contact your Loss Prevention Specialist for assistance or reference Cal-OSHA regulations here (3)

 

Q: How do I submit my data to Cal-OSHA electronically?

A: This information has not yet been provided from Cal-OSHA.  Fed OSHA, however, has communicated that it will provide a secure website for the electronic submission of information. The website will include web forms for direct data entry and instructions for other means of submission (e.g. file uploads). Fed OSHA anticipates this process will take an estimated 20-30 minutes in total.  It is reasonable to assume that a process similar to this will be instituted by Cal-OSHA.

Sources Cited:

(1)  https://www.osha.gov/Publications/OSHA3862.pdf

(2) https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf

(3) http://www.dir.ca.gov/dosh/etools/recordkeeping/details/details.htm

 

 

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