Electronic Recordkeeping – We’re Four Weeks Away… How to be prepared and What OSHA Has Said
We’re four weeks away from one of the most interesting OSHA regulation changes in recent history. The OSHA electronic recordkeeping policy brings with it the possibility for the agency to learn much more from the data by collecting it all in one digital database. However, the policy has many safety professionals and business owners a little concerned.
July 1, 2018 is the date everyone is expected to have their 2017 data submitted electronically. While most establishments got away with not submitting last December, OSHA has made it clear that they will not be as lenient this time. As a matter of fact, ensuring compliance with this policy will now be a part of any standard OSHA inspection:
“The Directorate of Technical Support and Emergency Management (DTSEM) will provide the Area Offices access to the ITA database containing the submitted Form 300As. CSHOs should refer to this database during all inspections in order to identify employers that were required to submit records but failed to do so.” – Directly from the Directorate of Enforcement Programs
So, what happens if a CSHO finds out that you didn’t submit your data?
OSHA has announced that if an employer subject to the rule says that it attempted to submit its records electronically but was unable to do so, it must verify this with documentation. Documentation can be defined as e-mail correspondence with the OSHA Help Desk, an OSHA National, Regional, or Area Office, or by using other OSHA contact means (such as e-correspondence). If such proof is provided, the CSHO shall collect the injury and illness records, and OSHA will not cite the employer for failing to submit.
If the employer was required to submit the data and did not attempt to do so, the Area Director shall issue a citation using the following guidance.
- If the employer failed to submit, but immediately abates during the inspection by providing a paper copy of the records, an Other Than Serious citation will be issued with no penalty.
- If the employer failed to submit its CY2016 data, but shows it has already submitted its CY2017 data, an Other Than Serious citation will be issued with no penalty.
- If the employer does not produce the records, an Other Than Serious citation will be issued with the appropriate penalty.
Now is the time for you to begin getting your data together. Submitting is relatively simple, just follow the instructions on the OSHA ITA .
Another solution many organizations are looking into is the Sospes system. This streamlines the entire safety reporting process. Your OSHA reports can be generated the second an employee reports an incident (from any mobile device) and Sospes will help you make sure that you’re never late submitting your data. Not only that, Sospes generates real-time analytic dashboards so you can begin tracking that very same data OSHA is collecting. Spend less time collecting papers and get back to improving the workplace by switching to the Sospes system today.
The official memo from OSHA
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