March 2 is Right Around the Corner

Beginning in 2019 employers that are required to electronically file their OSHA 300A form data will have to do so by March 2. OSHA had been phasing in the electronic rule and has recently finalized an updated rule affirming the March 2 date.

Employers with 20 or more employees (at any point in the calendar year) and in certain industries (agriculture is on the list) are required to send in OSHA 300A log summary data each year by March 2 of the following year. So what this means is that cotton gins that had 20 or more employees must send in their OSHA 300A log summary information to OSHA for calendar year 2018 by March 2, 2019.

The portal for submission of the data opened on January 2 of 2019. OSHA was one of the agencies that didn’t close during the government shut down. One of the changes that was made in the January rule making that modified this requirement is that beginning in 2020, the EIN number will be used to improve consistency of the data. Right now, slight changes in company name or information would result in appearing to be different companies to OSHA. Finally, OSHA has decided to NOT publish the information in the OSHA 300A data for now. Indications are that if it does decide to publish OSHA 300A summary data, it would likely do so without indication to whom the information belonged.

So, pull that OSHA 300A form off the wall. Take some time and read all the instructions carefully and go to the OSHA Portal and send in your OSHA 300A data. There are a number of instructions on the page and the RED Launch button (bar) is on the right side. Pay particular attention to the hours worked and what is considered recordable accidents. There’s no need in showing a high DART rate when it isn’t necessary. There is no reason to think that OSHA won’t use some of this information to target industries going forward. In fact, they have stated that this is one of the goals to collecting the data in the first place. We need to have good accurate data to make sure cotton ginning isn’t on some list some where in the future.

DF

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