Issue link: http://palletcentral.uberflip.com/i/893182
20 PalletCentral • September-October 2017 palletcentral.com In 2017, all covered employers will submit only data included on Form 300A; in subsequent years, establishments with 250 or more workers will also submit the data from Forms 300 and 301, while smaller operations will continue to provide only the summary data (Form 300A). The reporting deadline shifts to July 1 in 2018, and to March 2nd in subsequent years. The rule also contains anti-retaliation provisions, protecting injured workers from disparate treatment in incentive, discipline and drug testing programs, and that portion of the rule became effective on December 1, 2016. The rule is currently in litigation before the U.S. Court of Appeals, but the court declined to stay implementation while the case is pending. OSHA has provided a secure website containing its Injury Tracking Application (ITA), which offers three options for data submission. First, users will be able to manually enter data into a web form. Second, users will be able to upload a CSV file to process single or multiple establishments at the same time. Last, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface). OSHA anticipates it will take 10 minutes to create an account, and then 10 minutes to input or upload the data. No paper submissions will be accepted for compliance, and employers who lack internet access are encouraged to do their submissions from public facilities such as libraries, which offer free internet access. In launching its new system, OSHA clarifies that the size trigger is by establishment size, not firm size, because these records are maintained at the establishment level. Firms, by contrast, are often comprised of multiple establishments. Section 1904.46 of OSHA's recordkeeping regulation includes a definition of the term "establishment," which is key to this new reporting requirement. OSHA guidance states: An establishment is a single physical location where business is conducted or where services or industrial operations are performed. For activities where OSHA In launching its new system, OSHA clarifies that the size trigger is by establishment size, not firm size, because these records are maintained at the establishment level. Firms, by contrast, are often comprised of multiple establishments.