As the federal agency focuses on improving workplace safety, OSHA requires most employers to track, aggregate and submit yearly injury and illness records. In November 2013, OSHA first proposed moving larger companies and particularly hazardous industries to an electronic reporting system in hopes of streamlining the reporting process. By going digital, OSHA aims to improve compliance and reduce administrative burdens associated with recordkeeping and reporting requirements. The injury and illness data collected across industries can be aggregated and analyzed to identify trends, predict risks and develop improved, targeted safety regulations and procedures.
The Electronic Recordkeeping and Reporting System
Since January 1, 2017, companies with more than 250 employees, or companies in high-risk industries like construction with 20-249 employees, have been required to electronically track and submit injury and illness data to OSHA. Though some groups opposed the proposed rule change, claiming that digital records raised privacy and other security concerns, most who support the rule think it is an important step towards improving worker safety in the face of mounting challenges and risks. Indeed, as skilled workers retire and take decades of on-the-job safety knowledge and experience with them, contractors are having to rely on more inexperienced and undertrained workers, increasing the risk of potential injuries.
Importantly, electronic recordkeeping has the power to collect more accurate and robust injury and illness data. As the saying goes, if you can’t measure it, you can’t manage it, and with more information, various industry stakeholders can develop improved methods of reducing risks and improving safety. The data, for example, could be analyzed to determine what time of day, region or trade experiences the most injuries and illnesses – on a large-scale, national level. With this level of insights, OSHA and contractors can work together to improve training, refine protocols, and improve site safety.
Per the new electronic recordkeeping and reporting requirements, construction companies must do the following:
- Electronically submit their 2016 injury and illness reports by December 1, 2017 using OSHA form 300a.
- Submit forms 300a, 300, and 301 if they have 250 or more employees.
Companies must submit 2017 incidents electronically by July 2018, and starting in 2019, larger companies with 250+ employees must submit the previous year’s data by March 2nd of the following year. An important technicality to note is that the electronic injury and illness reports apply to each/every location where the company works. For example, if Company ABC has locations in 10 states, and each of those 10 locations has between 20 and 249 employees, Company ABC must submit electronic illness and injury reports for each location.
Though there is always some resistance to new rules and processes, it’s important to remember how accurate, digital records can improve our understanding of risks on the job. It is also important to leverage new tools and software that can make electronic recordkeeping and reporting simpler. For example, Spot-r automatically collects and documents safety incident information, including when, where, what type of incident and how severe (i.e. fall height), which can be used to compile injury and illness reports.
Risk management is about having the right information at the right time, and real-time digital records can streamline the analysis process to help keep workers safe.