22 PalletCentral • September-October 2017 palletcentral.com
those establishments meeting the size and NAICS criteria will
need to be submitted on or before December 1, 2017, and
thereafter. If an establishment is partially exempt from OSHA
recordkeeping due to industry code (e.g., an administrative
office location of a business), then no data should be submitted
for those establishments. OSHA has clarified that companies
may submit establishment-specific data for multiple
establishments, using a single account registration.
Third parties may also handle the submissions for the
employer, but legal responsibility for the accuracy of the
information remains with the employer. Furnishing false injury
or illness data to OSHA can be criminally prosecuted. In
addition, if the employer also gets a data inquiry from the
Bureau of Labor Statistics, it must still provide BLS with the
requested data, even if it was previously submitted to OSHA.
Technical information on how to submit data and ancillary
information about the final rule and OSHA requirements are
available at https://www.osha.gov/injuryreporting/index.html.
PC
OSHA
Adele L. Abrams is an attorney and safety professional who represents
companies in litigation with OSHA and also provides safety training
and consultation. The Law Office of Adele L. Abrams PC has three
offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be
reached at 301-595-3520 or www.safety-law.com.
OSHA has clarified that
companies may submit
establishment-specific data for
multiple establishments, using
a single account registration.
