April 18, 2019

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OSHA Proposes Delay of Compliance Date for Electronic Recordkeeping Rule

Earlier today, OSHA announced it plans to publish a formal proposal delaying the compliance date of the electronic recordkeeping rule.  The proposed delay follows last month’s announcement of OSHA’s intent to postpone the July 1, 2017 deadline by which certain employers would have been required to submit the completed 2017 Form 300A Summary of Work-Related Injuries and Illnesses.  OSHA now proposes to postpone the deadline to December 1, 2017.  According to OSHA, this would “provide the new administration an opportunity to review the new electronic reporting requirements prior to their implementation.”  The delay would also “allow affected entities sufficient time to familiarize themselves with the electronic reporting system, which will not be available until August 1.”  Comments on this proposal must be received by July 13, 2017.  Instructions for submitting comments are contained in the proposal.

OSHA stating the electronic reporting system will be available August 1 is an indication the agency intends to move forward with its implementation of the rule.  OSHA also notes, however, it “intends to issue a separate proposal to reconsider, revise, or remove other provisions of the prior final rule.”  Comments on that proposal will be sought in a separate federal register publication.

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About this Author

Daniel Flynn, Dinsmore Law Firm, Environmental and Safety and Health Attorney
Partner

Dan, a member of the Environmental Practice Group, focuses much of his practice on environmental, health and safety issues.

He has represented companies across general industry and construction with matters involving the Occupational Safety and Health Administration (OSHA), ensuring local and national clients minimize liability from OSHA enforcement actions by counseling clients on proper compliance with all OSHA standards and on proper inspection management techniques. If citations are issued, he helps clients develop and evaluate settlement...

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