For the past few weeks we’ve written articles and sent reminders that the deadline to submit your OSHA 300A form electronically was December 15th. OSHA has said they will continue to accept data for 2016 through December 31, 2017. So… IF you have not send in your information, please do so. More information can be found in this blog or by visiting the OSHA site on the electronic submission.
OSHA has not extended the deadline but all indications are that the late submissions will not have enforcement action because of them. They will no longer accept 2016 data after the end of this year so failing to submit your data by then would likely end up in an enforcement action if discovered.
In other OSHA activity, OSHA is considering some changes to its policy on these electronic submissions. One possible change wouldn’t affect gins but could make it a bit easier on larger employers. As the new rule is phased in, the larger employers (250 or more) would eventually end up sending in, not only the 300A information but also the 300 and the 301’s. OSHA has indicated that they may not be able to keep the personally identifiable information secret and therefore may only require the 300A in the future even for larger employers.
The second possible change would be to require businesses to submit their Employer Identification number. This would allow the Department of Labor to match the new data with the older Bureau of Labor Statistics data. That data was done by survey. Neither of these changes are even in the “Proposed Rules” stage yet but has shown up in the unified agenda.
To recap. If you had 20 or more employees in 2016 you are required to submit your OSHA 300A form electronically. The deadline for submission was December 15 but they will continue to accept late data through the end of the year. Please go to this site to submit your data if you haven’t done so yet. The only exception to this is gins in South Carolina are not yet required to submit data as their state has not adopted the federal rules yet.