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Now is the Time to Finish Your OSHA Recordkeeping for 2023

  • 02/01/2024

By Bob White
ROII Safety Director
 
You may have seen or heard about the new electronic reporting rules that went into effect on January 1, 2024. Many trade association websites have posted information regarding the new 100+ employee reporting rule. However, this is inaccurate information as the Washington State Department of Labor and Industries (L&I) has yet to adopt this rule officially. L&I does invite you to report this information if you choose, but the new rule is not law yet in Washington State for companies under DOSH (Department of Safety and Health) jurisdiction. 

An L&I spokesperson said the 2024 Reporting rule would most likely go through a CR105 expedited adoption process, but the reporting would still not become law until long after the March 2 electronic reporting deadline has passed, with June 3 being the projected date for adoption. However, certain companies that meet the reporting criteria should be prepared to do this reporting in 2025. It will entail information on certain types of injuries from the 300 Log, 301 Injury and Illness Incident Report, and the 300A Summary, which is posted from February through April for those companies required to do OSHA 300 Recordkeeping.

As always, any days away, restricted duty, etc., that run into 2024 for injuries that occurred in 2023 need to be recorded on the 2023 OSHA 300 Log, and information on the 300A summary amended Accordingly.

Establishments that employed two hundred fifty or more different employees
If your establishment employed 250 or more different employees during the course of the previous calendar year, and this chapter requires your establishment to keep records, then you must electronically submit information from OSHA Form 300A Summary of Work-Related Injuries and Illnesses to OSHA or OSHA's designee.

Establishments that both employed 20 to 249 different employees and are in designated industries
If your establishment employed 20 to 249 different employees during the course of the previous calendar year, and your establishment is in a designated industry listed in WAC 296-27-071 Appendix B, then you must electronically submit information from OSHA Form 300A Summary of Work-Related Injuries and Illnesses to OSHA or OSHA's designee.

This information and other helpful OSHA 300 resources can be found on L&I's website at:
https://www.lni.wa.gov/safety-health/preventing-injuries-illnesses/workplace-injuries-fatalities/#recordkeeping-osha-300-log

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