On August 1, 2017, OSHA finally launched its web portal to accept submission of recordkeeping forms pursuant to the requirements in the final rule, “Improve Tracking of Workplace Injuries and Illnesses.”  Under the rule, which was promulgated in May 2016, OSHA originally anticipated having the portal available by February 1, 2017, with submissions due by employers no later than July 1, 2017.  In May, OSHA delayed the launch of the portal until August 1, 2016.  While the web portal is now available, submission of recordkeeping forms is currently not required. OSHA has requested public comments on the proposed submission compliance date of December 1, 2017. All signs point to a December 1, 2017 compliance deadline for employers to submit their recordkeeping forms.

Under the rule, submission for all employers for 2017 is simply the 2016 300A Form.  Beginning in 2018, employers required to maintain injury and illness records with 250 or more employees at an establishment they will be required to submit all recordkeeping forms – 300 Log, 301 Forms and 300A Form.  For employers required to maintain injury and illness records with less than 250 but 20 or more employees in certain industries will be required to submit only they 300A Form.

The portal is called Injury Tracking Application or ITA and will accept three forms of data submission. Employers can manually enter the information into the online form, upload a CSV file or transfer the data electronically using an application programming interface (API).

OSHA has provided employers with “job aids” to assist in the development of a user account, password and uploading the data and has provided additional information in the form of FAQs. We encourage covered employers to take the time to become familiar with the portal, establishing an account and to carefully review their injury and illness recordkeeping forms prior to submission.

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Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.

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