Seyfarth Synopsis: On November 6, 2018, the California Office of Administrative Law approved Cal/OSHA's emergency regulation for the electronic submission of CY 2017 Form 300A on Occupational Injuries and Illnesses. Covered employers will be required to submit their Forms to Federal OSHA by December 31, 2018.
As we previously blogged, businesses operating in California that would be required to submit the CalOSHA Form 300A online include all establishments with 250 or more employees, unless specifically exempted by section 14300.2 of Title 8 of the California Code of Regulations, and establishments with 20 to 249 employees in the specific industries listed in Appendix H of the emergency regulation's proposed text (including common industries such as manufacturing, grocery stores, department stores, and warehousing and storage). The reporting deadline is December 31, 2018. Beginning in 2019, the reporting deadline would be March 2 of the year after the calendar year covered by the form(s). So, for example, CY 2018 300A Forms will need to be submitted by March 2, 2019.
Covered employers in California should submit their 300A summaries by following the instructions on federal OSHA's Injury Tracking Application webpage.
Although the formal rulemaking process needs to be finalized before the emergency regulations are permanent, including a public comment period and public hearing, employers should plan to meet the upcoming December 31, 2018 deadline. See any significant changes to the requirements summarized above.
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