Issue link: http://palletcentral.uberflip.com/i/713205
palletcentral.com PalletCentral • July-August 2016 29 government to identify emergent hazards that are harming workers, so that interventions can occur. The outcome of the e-Recordkeeping initiative will be the creation of the largest, publicly available, data set on occupational injuries and illnesses, more study of injury causation, and evaluation of the effectiveness of I/I prevention activities. OSHA has pledged that it will scrub personally identifiable information from the data before it is made publicly available. The release of personal information, or the ability to "reverse engineer" accident information in order to identify the victim, was among the concerns expressed by commenters during the rulemaking process. Although the e-Recordkeeping portion of the final rule becomes effective January 1, 2017, the first reports will not be due until July 1, 2017, at which time all covered employers will have to submit the Form 300A (Summary of Work-Related Injuries and Illnesses) only. In calendar 2018, establishments with 250 or more employees will have to submit Forms 300A, Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) by July 1, 2018. Establishments with between 20-249 employees that are classified by NAICS code in certain industries that have historically high rates of occupational injuries and illnesses will have to file electronically, but their submission requirement is limited to the summary, Form 300A. The pallet manufacturing and warehousing/logistics sectors are included in this category. The e-Recordkeeping requirements are codified at 29 CFR 1904.41. Beginning in 2019, the submission deadline for filing the mandated reports will move to March 2nd (instead of July 1st). The rule retains the provision that permits OSHA to collect information from other employers, who will not submit the information to the agency routinely electronically, upon written notification from OSHA or its designee. States that manage their own OSHA programs (22 states cover private sector employers and are designated as "state plan states") will have to adopt requirements that are substantially identical within six months from May 12, 2016. Section 11(c) of the OSH Act provides workers with protection against retaliation or discrimination for engaging in protected activities, which has always included the right to report injuries and illnesses to the employer. The new rule contains provisions to make discrimination illegal and subject to OSHA civil penalties: • Employers must inform employees of their right to report work-related injuries and illnesses free from retaliation. This obligation can be satisfied by posting the April 2015 (or later) version of OSHA's Job Safety and Health – It's the Law poster