“OSHA’s E-Recordkeeping Deadline Extended Again – Stroke of Midnight December 31, 2017”

We have closely tracked the Trump Administration’s treatment of OSHA’s new E-Recordkeeping and Anti-Retaliation Rule, and while there have been plenty of signals that this rule is due for an overhaul, or even possibly to be rescinded entirely, no such action was taken to interfere with the first required data submission, other than to extend the deadline from this summer to December 15th, and now to December 31st, for all intents and purposes.

The OSHA Defense Report

By Eric J. Conn

The December 15, 2017 deadline for large employers and small employers in certain “high hazard industries” to submit injury and illness data to OSHA has just passed, but it is not too late to submit injury data without being cited by OSHA for missing the deadline.  OSHA announced today that will continue to accept employers’ 300A annual summary injury data for calendar year 2016 through the agency’s new Injury Tracking Application (ITA) (the portal that will receive the injury data) until midnight on December 31, 2017, and will not take any enforcement action against those employers who submit data between now and then, even though the submissions would technically be late.  Beginning January 1, 2018, the portal will no longer accept 2016 data.

We have closely tracked the Trump Administration’s treatment of OSHA’s new E-Recordkeeping and Anti-Retaliation Rule, and while there have been plenty of signals…

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“@OSHA_Guy [Free Webinar] OSHA Status of Pres. Trump’s Agenda for the “Deconstruction of the Administrative State” – August 15th, 1:00pm ET”

Free Webinar Date: Tuesday, August 15, 2017 Time: 1:00pm to 2:30pm ET Your Hosts: Eric J. Conn, Kate M. McMahon, Amanda Strainis-Walker, and Micah Smith President Trump was carried to the White House on promises (or threats) of rolling back government regulations.  At the CPAC conference this year, Pres. Trump’s Sr. Policy Advisor, Steve Bannon, framed much of … Continue reading “@OSHA_Guy [Free Webinar] OSHA Status of Pres. Trump’s Agenda for the “Deconstruction of the Administrative State” – August 15th, 1:00pm ET”

“Is That My Employee? Multi-Employer, Joint-Employer, Independent Contractors and Temp Workers” @OSHA_Guy

Employers must beware as the U.S. Department of Labor (“DOL”) cracks down on what it perceives as rampant misclassifying employees as contractors and shirking other responsibilities, such as safety training, because a worker is supplied by another employer.  With more and more unique employment relationships and multi-employer worksites, it is crucial to understand the complexities … Continue reading “Is That My Employee? Multi-Employer, Joint-Employer, Independent Contractors and Temp Workers” @OSHA_Guy

“A Look At OSHA’s Severe Violator Enforcement Program”

OSHA has finite resources, and it would take decades for the agency to visit every employer in the country to ensure workers are being protected. OSHA officials often have said that most employers are doing their best to keep workers safe. Yet employers who actively ignore safety regulations and put employees in danger are out … Continue reading “A Look At OSHA’s Severe Violator Enforcement Program”