To Electronically Submit Data or Not? That Is the Question

The Form 300A electronic submission saga continues for California employers.

We begin a new act in the continuing drama of will California employers need to electronically submit Form 300A data or not. On May 9, the California Division of Occupational Safety (also known as Cal/OSHA) will meet to evaluate the electronic submission of workplace injury and illness records.

First, let’s give a little background. In May 2016, the federal Occupational Safety and Health Administration (OSHA) published a final rule on “Improve Tracking of Workplace Injuries and Illnesses” and required employers in certain industries to electronically submit injury and illness data (Form 300A, Annual Summary of Work-Related Injuries and Illnesses), which employers were already required to keep, starting January 1, 2017.

At first, California didn’t need to follow these requirements – OSHA gave states that operate their own health and safety programs, such as California, extra time to implement the new requirements. Then, in April 2018, OSHA announced that states that had not yet adopted regulations as effective as the federal regulations were now required to electronically submit this data. In response, Cal/OSHA approved emergency regulations requiring employers to electronically submit this data by December 31, 2018.

Cal/OSHA’s advisory meeting will evaluate how to implement changes necessary to protect the goals of the original “Improve Tracking of Workplace Injuries and Illnesses” rule. You can find meeting information on Cal/OSHA’s website. The public can email any written comment to by 5 p.m. on Friday, May 24.

The public meeting will be held on Thursday, May 9, 2019, from 10 a.m. to 3 p.m. at:

The Elihu Harris Building
1515 Clay Street Suite 1304
Oakland, CA 94612

Stay tuned to HRWatchdog for more updates.

Katie Culliton, Editor, CalChamber

CalChamber members can read more about Recording Work-Related Injuries and Illnesses in the HR Library. Not a member? See what CalChamber can do for you.

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