January 19, 2021

Volume XI, Number 19


January 18, 2021

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OSHA Delays Online Record-Keeping Rule and Opens Proposal for Comment

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. 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.

© 2020, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., All Rights Reserved.National Law Review, Volume VII, Number 179



About this Author

Melissa Bailey, Ogletree Deakins Law Firm, Occupational Safety Litigation Attorney

Melissa Bailey focuses her practice on occupational safety and health issues, and also serves on the Firm's Board of Directors. She litigates OSHA cases before federal and state agencies and courts, and also represents employers during government inspections and investigations. Her practice also includes providing compliance advice and conducting privileged audits on complex workplace safety issues. Melissa represents employers in a wide range of industries, including electric utilities, chemical manufacturing/refining, retail, food processing, construction, and drug...

Matthew Linton, Ogletree Deakins Law Firm, Labor and Employment Litigation Attorney
Of Counsel

Matthew Linton advises clients on a broad range of workplace and environmental safety and health issues, employment matters, and government investigations throughout the nation. He routinely handles the legal and crisis response to workplace accidents and fatalities and safety related whistleblower complaints with agencies such as OSHA, MSHA, CSB, DOT, EPA, and others. Linton also crafts risk management strategies to avoid government entanglement with a variety of federal and state agencies.