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Fall is a Time of Change and OSHA is Changing with the Season

Just when we thought we heard enough from OSHA, we learned we were wrong. OSHA rules are changing again. Effective November 1, 2016 there will be new reporting requirements phasing in over the next 2 years.

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by
March 2.

Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule. See OSHA’s website at https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf

For small business owners it is critical that you click on the link above for high-risk industries. When I did, I was shocked to learn that most businesses I work with are on that list!!!

November 1, 2016 brings one more OSHA rule to be followed (MIOSHA must adopt a nearly identical rule within 6 months): Anti-retaliation…

This rule prohibits employers from discouraging workers from reporting an illness or injury in the workplace. It requires employers to inform their employees of their right to report work related illnesses and injuries free from retaliation (Prediction: I see a new labor poster change coming soon!!). It also requires that employer reporting protocols be reasonable and not deter the employee from reporting. This can include such issues as mandatory drug screens with any injuries. This could be seen as discouraging the employee from reporting an injury. For more information, click on the following link: https://www.osha.gov/recordkeeping/finalrule/index.html.

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