Updates to OSHA’s Recordkeeping and Reporting Rule: www.osha.gov Updates to OSHA’s Recordkeeping and Reporting Rule: What events must be reported to OSHA and which employers have to keep records Occupational Safety and Health Administration

Expanded reporting requirements www.osha.gov Expanded reporting requirements The rule expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. Starting January 1, 2015 employers must report the following to OSHA: All work-related fatalities within 8 hours (same as current requirement) All work-related in-patient hospitalizations of one or more employees within 24 hours All work-related amputations within 24 hours All work-related losses of an eye within 24 hours All covered employers must report all work related fatalities to OSHA within 8 hours: All work related in patient hospitalizations to OSHA within 24 hours (previous requirements were to report only 3 inpatient hospitalizations) All work related amputations to OSHA within 24 hours All related losses of any eye to OSHA within 24 hours Please note: In-patient hospitalization is defined as a formal admission to the in-patient service of a hospital or clinic for care or treatment. Only fatalities occurring within 30 days of the work-related incident must be reported. Only in-patient hospitalizations, amputations, or losses of an eye occurring within 24 hours of the work-related incident must be reported. Employers do not have to report an event if: It resulted from a motor vehicle accident on a public street or highway, except in a construction work zone (employers must report the event if it happened in a construction work zone). It occurred on a commercial or public transportation system (e.g. airplane, subway, bus, ferry, street car, light rail, train). It occurred more than 30 days after the work-related fatality or more than 24 hours after the work-related in-patient hospitalization, amputation, or loss of an eye. If the in-patient hospitalization was for diagnostic testing or observation only. We will not respond to every report with an on-site inspection. We expect to address many of the reports through other types of investigations, but we will engage with employers whose workers have been hurt. We are developing the process to determine which incidents to inspect and which to handle using other types of investigations and interventions.

Expanded reporting requirements Method of reporting: By telephone to the nearest OSHA Area Office during normal business hours. By telephone to the 24-hour OSHA hotline (1-800- 321-OSHA or 1-800-321-6742). Electronically through OSHA's website.

Nationally, over 10,000 severe injuries were reported by employers in 2015. Over 7,600 Hospitalizations

Over 2,600 Amputations

ELECTRONIC SUBMISSION OF OSHA INJURY AND ILLNESS RECORDS Annual Submission of Records Required All Employers with 250 or more employees: Must submit OSHA 300A by July 1, 2017 Must submit OSHA 300A, 300, and 301 by July 1, 2018 Must submit OSHA 300A, 300, and 301 by March 2, 2019. Employers with 20 to 250 employees in Designated Industries: Must submit OSHA 300A by July 1, 2017 and July 1, 2018 Must submit OSHA 300A by March 2, 2019 Employers must also submit records if notified by OSHA for individual data collection

ELECTRONIC SUBMISSION OF OSHA INJURY AND ILLNESS RECORDS New regulation also contains two new areas Employee Involvement: How to report Information about this regulation Access to injury and illness records Procedures for reporting an injury/illness Information about anti-discrimination for reporting Prohibition for Discrimination – An employer cannot discriminate against an employee for reporting an injury, illness, or fatality

NEW PENALTY STRUCTURE Federal Civil Penalty Adjustment Act passed by Congress on Nov 2, 2015 Agencies must increase penalties retroactive to last increase based on CPI. OSHA is approx 78% increase

NEW PENALTY STRUCTURE TYPE OF VIOLATION PENALTY MAXIMUM Serious $12,471 Other-than-Serious Posting, Non Reporting Willful or Repeat $124,709 Failure to Abate $12,471 per day

NEW PENALTY STRUCTURE Adjustment Factor for Size of Employer Employees Percent Reduction 1 – 10 70 11 - 25 60 26 - 100 30 101 – 250 10 251 or more None