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.

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Is your OSHA 300 Form Posted?

OSHA has put a lot more emphasis on the tracking and recording of accidents and injuries. The obvious thought is that you can’t improve what you don’t measure. For years almost all employers have been required to keep track of their accidents and injuries via the OSHA 300 form. You should have 5 calendar years of OSHA 300 forms in your files. Additionally OSHA has now begun collecting the OSHA 300A information from nearly everyone that needs to keep a 300 form. The next electronic submission will be sometime this Summer.

The 300A summary of accidents and injuries are supposed to be posted each year beginning Continue reading

OSHA Will Continue to Accept 2016 OSHA 300A’s A Few More Days

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 Continue reading

Its Time to Send in your OSHA 300A’s

This has been a back and forth issue for some time. We were hoping the time wouldn’t come but it’s looking more evident that the time has come to send your 2016 OSHA 300A forms to OSHA.

Last year, OSHA released a new regulation on record keeping and reporting of injuries and illnesses. Originally, all employers with 20 or more employees at any point in the year in certain industries (including agriculture) needed to submit their OSHA 300A (Summary) data from calendar year 2016 to OSHA buy July of 2017. Under the new administration, that date was postponed and a proposed rulemaking came out that delayed the deadline for submission to December 1. The site for submittal of the 300A information went up in mid August.

We have continued to hear that OSHA will be making some changes to the rule but what those changes were have not been leaked. The hope was they would get rid of the Continue reading

Congress Hits Back At OSHA

Earlier this month you may have heard about OSHA getting beat up by Congress over the Volks Rule. There was a lot made about this in the political press over the past couple weeks and while many are fist pumping “hell yeah” they have no idea what actually happened. The issue is somewhat tedious but typifies the perceived abuse of authority many businesses saw under the previous administration.

To understand what happened and what didn’t happen earlier in the month we need to understand a little about a process (the reason for this article). OSHA derives its authority from the Occupational Safety and Health Act. The ACT (or law) is what established and grew OSH Administration (government agency). OSHA, under its authority can make rules to implement the law. They issue citations for violations of the law and rules (have the effect of law). If a cited company contests the citations, there are several steps in the process to get to an administrative law judge…then possibly an actual federal appeals court.

In the Volks decision, the Court told OSHA it didn’t have the authority to cite a company for failing to record an injury on the OSHA 300 form more than 6 months after the time it should have recorded it. The court said there’s a six month statue of limitations under the OSH Act Continue reading

Have You Posted Your OSHA 300 Yet?

Have you posted your OSHA 300 yet? All gins should have the OSHA 300 forms posted in a conspicuous place by now. These forms are to be put up no later than February 1 each year and stay posted until April 30. If you haven’t gotten it up, now is a good time to get it done.

The OSHA 300 is the annual summary of injuries and illnesses at a business. All recordable injuries for calendar year 2012 are to be in the log and the summary posted. This is one of the most commonly cited OSHA violations each year and should be one of the easiest to avoid.

The 300 log can be downloaded from the OSHA site at Before posting the form, make sure it has been reviewed for completeness and signed by a responsible individual. The instructions for the form are included when you download the 300 as well as on the cite itself. You only need to post the form, not send it in to OSHA normally. If you receive a written request to send OSHA a copy of your data, please let us know. Only a few gins get selected to report each year.

Don’t hesitate to call Barry or myself if you have questions about this posting and recordkeeping.