OSHA 300 Electronic Reporting for 2020

Understanding government regulations is tough enough, but it gets even tougher when the government asks for a report. How is a small business supposed to keep up? 🙄

OSHA launched its online reporting nationally but there was heavy resistance from the private sector regarding the rule and it went into litigation.  

After a final ruling, Washington state was been able to update its rule. 

To summarize:  

Who is required to submit the OSHA 300 electronically? 

The latest guidance gives a list of criteria you must use to determine if you’re required to use the electronic OSHA 300 submission.  

Effective 1/1/20 the OSHA 300A (summary only) is required to be electronically submitted, if: 

1. At any time during the previous year the employer employed 250 or more employees at an establishment and are not exempt. 
2. At any time during the previous year the employer had at least 20 employees at an establishment and are in a designated high-risk industry, as defined in: 
   • WAC 296-27-071 
   • Appendix B (pages 25 & 26)  
3. If an employer has several establishments that meet the criteria for electronic submission, each establishment must create a 300A and electronically submit separately.   
4. The employer is required to submit the 300A electronically to OSHA and they receive an additional request from the Bureau of Labor and Statistics, employers must report to both agencies. 

Important FAQ 

Q: Are the electronic reporting requirements based on the size of the establishment or the size of the employer?  

A: The electronic reporting requirements are based on the size of the establishment, not the firm (employer). To determine if an employer needs to electronically submit for each establishment, the employer must determine the peak employment at an establishment during the last calendar year. Everyone working at the establishment, at any time during the calendar year, counts as one employee including full-time, part-time, seasonal, and temporary workers.  

Q: What is considered an establishment?  

A: An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. 

Confused? Don’t worry! See below for information on our client training sessions coming up this month.  

OSHA 300 requirements training 2020 

Approach is holding three client trainings in January to help clear things up when it comes to OSHA 300. Register now so you’ll know what electronic reporting means for you. We’ll also help get you ready for the February 1-April 30 period when the OSHA 300 must be posted in your workplace, with advice on: 

• How to complete the OSHA 300 Log of Work-Related Injuries and Illnesses  
• How to complete the OSHA 301 Incident Report. 
• What is recordable 
• What is considered first aid 
• Posting requirements  
• Confidentiality of records issues, and more! 

OSHA 300 Training dates and locations 

• January 7, 2020, 9 a.m. – via webinar 

• January 14, 2020, 9 a.m. – at the Approach office in Seattle (1711 S. Jackson St) 
• January 22, 2020, 9 a.m. – via webinar 

All trainings are only open to Approach-managed retro groups, including members of SMART and PITB. There is no cost to attend but you must pre-register (use the links above or go to www.pitb.wpengine.com/events). 

Finally, remember that L&I claims are not the same as OSHA-recordable accidents. You may need to record an accident even if no claim is filed, and vice versa. Approach can provide claim information to help with your OSHA 300, but you need to review it carefully to ensure your reporting is accurate. That’s why the OSHA 300 trainings are so important for all Approach clients, so register now!