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OSHA Enacts Rule Requiring Electronic Injury and Illness Recordkeeping


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On May 12, 2016, the Occupational Safety and Health Administration (OSHA) published its final rule on electronic recordkeeping of workplace injuries and illnesses. This new rule will require many employers to electronically report injury and illness data to OSHA annually; contains requirements for employee involvement in injury and illness reporting; and prohibits retaliation on the part of employers when employees report workplace injuries and illnesses.

Under this rule, Electronic Submission of Injury and Illness Records to OSHA, 29 C.F.R 1910.41, OSHA will collect and publish employer injury and illness records on osha.gov, and may use this data to target inspections. OSHA has stated that in making employer data public it is relying on “behavioral economics” to encourage employers to prevent injuries.

Existing OSHA regulations require employers with more than 10 employees in many industries to keep records of occupational injuries and illnesses and post an annual summary at their establishments. This will not change under the new rule. Only those establishments with 20 or more workers are affected by the additional electronic recordkeeping requirement.

The phased timetable for initial and on-going electronic reporting required elements is below.

July 1, 2017 July 1, 2018 March 2, 2019
(and every March 2 thereafter)
Non-Exempt Establishments*
with 250+ Employees
2016 OSHA
Form 300A Summary due
2017 OSHA
Forms 300, 300A, and 301 due
Prior year’s OSHA Forms
300, 300A, and 301 due
Employers in “High Risk”
Industries** with 20-249
Employees per Establishment
2016 OSHA
Form 300A Summary due
2017 OSHA
Form 300A Summary due
Prior year’s OSHA Form
300A Summary due


Access the Aon Risk Alert to learn more about the new law and the industries that are impacted.

Contact the Experts

Mark Sullivan
Senior Consultant
Aon Global Risk Consulting
Casualty Risk Control
1.513.562.4545
Deborah E. Weigand
Managing Director
Aon Global Risk Consulting
Casualty Risk Control
1.248.936.5217