OSHA Injury and Illness Recordkeeping Deadline Extended
Posted December 4, 2017

California employers now have until December 15, 2017, to submit the 2016 OSHA Form 300A (see https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-25392.pdf). Covered establishments include: (1) Establishments with 250 or more employees at any time during the year in covered industries, and (2) Establishments with 20-249 employees at any time during the calendar year in covered "high hazard" industries. For covered establishments with business operations outside of California, remember that this year’s submission must be done electronically at the following website: https://www.osha.gov/injuryreporting/ita/ (note, however, that Maryland, Minnesota, South Carolina, Washington and Wyoming are also excluded from the electronic filing requirements).

To date, California has not yet adopted an OSHA-approved State Plan, and until it does so, California employers are not required to file their OSHA Form 300A electronically. (https://www.dir.ca.gov/dosh/calosha-updates/log300-reporting.html). According to the DIR website, “California employers are not required to follow the new requirements and will not be required to do so until "substantially similar" regulations go through formal rulemaking, which would culminate in adoption by the Director of the Department of Industrial Relations and approval by the Office of Administrative Law. Cal/OSHA drafted a proposed rulemaking package to conform to the revised federal OSHA regulations by amending the California Code of Regulations, title 8, sections 14300.35, 14300.36, and 14300.41. The package is currently under review within the Administration.”

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