February 10, 2020 Safety Tip of the Week delivered to your inbox each Monday by GrainnetSafety.com
Electronic Submission of OSHA Injury and Illness Records
What is electronic recordkeeping reporting?
If you have 20 to 250 employees in one location, you are required to submit injury and illness records to OSHA once a year, this year by March 2, 2020.
OSHA classifies these NAICS industries as “high risk."
OSHA 1904.41(a)(2) covered industries:
Agriculture, forestry, and fishing (NAICS 11).
Utilities (NAICS 22).
Construction (NAICS 23).
Manufacturing (NAICS 31-33) FEED MILLS.
Wholesale Trade (NAICS 42) GRAIN ELEVATORS.
Industry groups (4-digit NAICS) with a three-year average DART rate of 2.0 or greater in the retail, transportation, information, finance, real estate and service sectors.
Since grain elevators NAICS is 424510, and feed mills NAICS is 311119, they both fit into OSHAs high-risk industry.
According to OSHA, the “employer” is an individual establishment (i.e. single physical location) where business is conducted or where services or industrial operations are performed. So how do I calculate my number of employees?
The electronic reporting requirements are based on the size of the establishment, not the firm.
A firm may be comprised of one or more establishments.
Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.
So you must have 20 employees in one location to be required to do the electronic recordkeeping. Remember seasonal workers count.
So, at any single facility if you have 21 employees counting seasonal, you would be required to submit electronic records to OSHA.
All companies still are required to complete the OSHA 300, 300A, and the 301 forms.
The records must be maintained at the worksite for at least five years.
Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year.
Also, if requested, copies of the records must be provided to current and former employees or their representatives.
