Cal/OSHA Issues Emergency Rules for Posting Injury Forms Electronically

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Cal/OSHA is implementing emergency regulations that require California employers with 250 or more employees to submit their 2017 Form 300A summaries electronically by the end of this year. That’s the form that you signed and posted in your workplace from Feb. 1 to April 30. Form 300A contains only the summary of injuries and is not the actual log, which contains the names of the employees who were injured. For the electronic filing, you will simply take the same information on the form you posted earlier this year and enter it into an electronic database. The short ramp-up period will require employers to quickly act to comply with the emergency regulations, which were approved by the state’s Office of Administrative Law in early November. The new regulations were implemented on an emergency basis to put California’s regulations on par with those of Federal OSHA. Who do the new rules apply to? The new regs apply to the following employers:
  • Those with 250 or more employees, unless specifically exempted by section 14300.2 of Title 8 of the California Code of Regulations.
  • Certain employers with 20 to 249 employees in specific industries that are listed in Appendix H of the emergency regulations.
Among the industries in the latter category are:
  • Agriculture
  • Construction
  • Manufacturing
  • A number of retail businesses
  • Transportation
  • Warehousing
  • Health care
You can find a full list of the above industries on pages 8-10 in Cal/OSHA’s emergency regulations: www.dir.ca.gov/dosh/doshreg/Recording-and-Reporting/Text-of-Amended-Regulation-Revised.pdf Employers that do not have to fill out OSHA logs include:
  • Those that had 10 or fewer employees during the entire year; and
  • Those that have 20-249 employees, but their industry does not fall within the list of “high-risk industries,” as above.
After this catch-up period at the end of the year, all applicable employers will be required to submit their Form 300A electronically every year going forward. Until Cal/OSHA promulgates new regulations to make that a permanent rule, the agency advises all applicable employers to follow the instructions on Fed-OSHA’s “Injury Tracking Application” webpage: www.osha.gov/injuryreporting/index.html Cal/OSHA will be implementing its own online tool and when it does, we will notify you.


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