The Occupational Safety and Health Administration (OSHA) plans to publish a proposed rule on June 28, 2017 to delay the electronic reporting deadline which certain employers must file the OSHA Form 300A. The proposed rule would delay the compliance date from July 1, 2017 to December 1, 2017.


On May 12, 2016, OSHA published a final rule that intended to improve tracking of injuries and illness in the workplace. Under this rule, an initial deadline of July 1, 2017 was set for employers to submit information from their completed 2016 Form 300A electronically to OSHA. It was the intent of the Agency to launch a data collection system in February 2017, which employers could use to submit the Form 300A data; this launch has been postponed and the new launch date, according to the proposed rule will take place by August 1, 2017.


Proposed Rule
The proposed electronic reporting deadline of December 1, 2017 for the 2016 Form 300A will give employers a four-month window to electronically submit the form data after the OSHA data collection system launches. The reporting delay also provides the new administration an opportunity to review the new electronic reporting requirements before implementation.


OSHA is seeking comments on the proposed delay and has stated that they also intend to issue a separate proposal to reconsider, revise, or remove other provisions of the prior final rule, which will have its own separate comment period.


You can now view the proposed rule, “Improve Tracking of Workplace Injuries and Illness: Proposed Delay of Compliance Date.”


Paylocity will continue to monitor the progress of OSHA electronic reporting, as well as any additional future proposed rules that affect OSHA reporting requirements.


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This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a payroll service provider are encouraged to seek the advice of a qualified CPA, tax attorney, or advisor.