Rule Also Has Potential Ramifications for Employers’ Post-Accident Drug-Testing Policies

OSHA recently released its Final Rule on the electronic recording and submission of injury and illness records. The Rule has several important provisions of which employers need to be aware, as well as some potential ramifications to long-standing employer practices.

Here are the basic requirements under the new Rule:

• Employers with 250 or more employees that are currently required to keep OSHA injury and illness records must electronically submit information from their OSHA 300, 300A, and 301 forms to OSHA
• Employers with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses must electronically submit information from their OSHA 300A forms to OSHA
• All employers required to do so must still otherwise maintain their OSHA 300, 300A, and 301 forms at their respective establishments

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