After a long and arduous process of proposals and challenges, Federal OSHA has finally released its new Injury Tracking Application (ITA). OSHA’s intent to track employee injury data electronically caused no small stir when first proposed. The entire concept seemed to polarize people, with many having strong thoughts as to whether the concept would have positive or negative repercussions.
Initial—and ongoing—concerns centered around: 1) the public availability of companies’ loss data; 2) the potential inequality of company-to-company comparisons, based on similar NAICS codes which can encompass companies that some feel should not be compared; and 3) concerns over the possibility of increased enforcement actions. These three concerns, as well as concerns over the logistics and time involved to report, lead to legal challenges which delayed the actual standard for a while and which are ongoing.
Other concerns centered around items included in the preamble to the regulation which seemed to decrease an employer’s ability to enact and maintain certain types of safety incentive programs. OSHA’s long-time contention is that electronic data will enable them to find and correct safety performance problems. There has also been talk of additional public pressure to be put on companies whose safety data appears to be problematic.
Despite the legal challenges and concerns, OSHA has launched the tool they intend to utilize to track this data. The tool is available now, and employers have until December 1, 2017 to start using it. If you would like to be an early adopter simply sign up on the OSHA website.
Employers will have the option of signing up by either entering their data manually, uploading a specific CSV (Comma Separated Values) format, or even using an API (Application Programming Interface). The first year, the only data employers will have to enter or upload is the data from the 300A summary for each establishment. As before, some industries are partially exempt.
Certain higher-hazard industries with fewer than 250 employees will have to go above and beyond the rest by entering more information starting in 2018.
All organizations with 250 or more employees will have to enter information from all OSHA record-keeping forms starting in 2018.
Each state plan OSHA state will have to decide how they are going to handle some parts of this standard. Most will likely follow suit using the Federal standard and tool.
If you have any questions about this process, please feel free to reach out to me at email@example.com, or your Woodruff Sawyer representative.
Steven Glazier is Vice President, Casualty Loss Control Specialist in the firm’s Denver office. With over 22 years in injury prevention and 16 years in insurance, Stephen has a unique cross-expertise in safety and loss control. His areas of expertise include ergonomics, safety KPI development, safety program gap analysis and OSHA compliance.