In May of 2016, OSHA issued a final rule to revise its Recording and Reporting Occupational Injuries and Illnesses regulation. This rule requires employers in certain industries to electronically submit injury and illness data. This final rule was effective on January 1, 2017.
The injury and illness data in question is already required to be collected and kept by employers, and is often maintained on paper forms and logs. The final rule mandates that this data be submitted in an electronic format — making it easier to aggregate, analyze and learn from the data as the reporting methodology moves from analog to digital.
In addition, electronic reporting simplifies the dissemination of collected data. According to the agency's website, “Behavioral economics tells us that making injury information publicly available will ‘nudge’ employers to focus on safety.” Needless to say, this sentiment is not universally accepted. Some see the new electronic reporting requirement as an unnecessary burden on employers, providing ammunition to unions and labor during contract negotiations. Others say it does little to actually improve safety — merely highlighting flaws, but doing nothing to address them.
Not so fast
No matter your point of view, there are new federal reporting requirements and companies must comply, starting...um...at some point in the not too distant future...in all likelihood.
The final rule took effect on January 1 of this year and requires employers to submit summary data electronically by July 1 — as in just a few days from now. However, there is no need to panic and begin scrambling to comply. While OSHA announced it was launching a website to accept electronic submissions, that site has never gone live and the agency has announced its intent to propose a delay in electronic filing. Translation — there is no need to spend the rest of your week preparing for electronic submission of injury and illness reports, and you can instead plan your 4th of July picnic menu and remind your employees about the safety hazards of holiday fireworks.
Paper producers should not get too comfortable
With the relaxation of the electronic reporting deadline, some may assume that paper versions of forms and logs will be around for a long time to come and those individuals charged with completing those documents by hand can again rejoice at their extended job security.
However, time marches on and in all likelihood this is a matter of when, not if. At some point in the not too distant future, the benefits of electronic reporting will likely outweigh concerns and this information will no longer be collected the old fashioned way.
It is, after all, 2017 and completing these forms and logs on paper and storing them in filing cabinets makes little sense in terms of productivity and efficiency.
So what IS the question?
Regardless of when the electronic submission of worksite injury and illness data begins, electronic tools can be leveraged today to simplify the collection and recording of required data. In other words, why in the world are employers still filling out paper documents?
Filling out those pesky forms and logs no longer has to be done manually — data captured electronically is automatically rendered on OSHA documents — documents which are stored electronically and can be printed on demand. The labor intensive effort associated with assembling information and filling out forms by hand is all but eliminated.
And when (ok, possibly even if) the time comes to report all of this electronically, doing so will be a snap, as the data is already managed electronically and we are prepared to help our clients submit rapidly and easily.
Regardless of the timetable for electronic submission, do yourself a favor and make sure the information required is being collected and curated electronically.