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The deadline for OSHA's NEW E-Recordkeeping submission is December 15th: what should I do? 

Tamara Parris

To learn about how to submit your OSHA E-Records electronically, join us on Wednesday December 13 at 11:00 am for a live discussion with @ericconn, @danieldeacon and @augustinechan

Register Link:

Our EHSQ Community members will walk you through how to submit your records on the OSHA site, using a .cvs file format. Whether you use excel or a software management  system, we have you covered!

During our pre-event planning session, I had the opportunity to do a short interview with @danieldeacon and @augustinechan before the live session to learn more on the OSHA topic.

Question EHSQ Community: With the moving toward electronic submission of data, do you see a potential for the misuse of the collected data by OSHA? 

Answer Dan Deacon of Conn Maciel Carey LLP: 

We are not sure how OSHA will use the data. What we do know is the number of employers submitting data to the Department of Labor is being quadrupled. Given such a substantial increase, it will be interesting to see if OSHA staff will be able to manage such a substantial increase in data. This is a whole new system for the data collection. There have been no public announcements yet, so we will have to wait and see what the agency plans to do with the data.

Question EHSQ Community: What are the top value adds of using a software system to track and submit OSHA data? 

Answer Augustine Chan of Intelex Technologies: 

The software will help to make the tracking of your organizations data easier. This will enable you to concentrate on the data entry and analysis portions. The system will help you organize the data and place them in the right buckets to give insight into your business.

It will make it easier for you to:

  1. Analyze the data. The data is easily searchable, compared to excel where the data looks overwhelming 
  2. Leverage the management system business intelligence tools, such as the reporting and dashboards, which will provide insights to target risk areas in your business, and easily address other safety and quality business goals and targets. 
  3. Increase your understanding of the incident details, and proactively plan. It is not just about reporting an injury, but really closing it and making sure it is investigated properly. This helps to better understand the details associated with the incident, so you can be proactive in your planning to mitigate it from occurring again in the future. You can integrate your data with other management systems to get closer to an integrated management system. You can then compare various areas of your business with each other. This helps to paint a larger picture of the business.


Question EHSQ Community:  What do I do if I am facing an OSHA recordkeeping citation? 

Answer Dan Deacon of Conn Maciel Carey LLP 

While OSHA’s six-month statute of limitations for recordkeeping violations has run for purposes of violations related to your 2016 data, there are a number of steps you should take if you do face a recordkeeping citation.  Employers should contact counsel to obtain advice on how to defend a recordkeeping citation as soon as possible. 

Counsel will want to speak to the company representative responsible for injury and illness recordkeeping, and review the following:  

  1. Injury and illness records, 
  2. Workers’ compensation records, and
  3. Company recordkeeping policies.
December 12, 2017 @ 10:04 AM EST Health & Safety, Risk Management

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