On June 27, 2017, the Occupational Safety and Health Administration (OSHA) proposed to delay the compliance date of the Obama-era regulation requiring electronic submission of injury and illness records and online public access to such records. OSHA recently announced that it would propose delaying the July 1 deadline for employers with establishments of 25 or more employees to submit Form 300A electronically. 

Originally planned for an effective date of July 1, 2017, we noted last month that OSHA intended to delay implementation to a future date. OSHA has now published a notice of proposed rulemaking delaying the effective date until December 1, 2017. OSHA will accept public comments on the proposal to delay the compliance date through July 13, 2017.

Notably, the delay does not address one of the most controversial provisions of the electronic record-keeping rule: The requirement that OSHA make employers’ injury and illness data publicly available online.

Stay tuned . . . Ogletree  Deakins will continue to monitor developments and will provide updates on the firm’s Workplace Safety and Health blog as they become available. 


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