The OSHA Electronic Submission of Injury and Illness Records rule became effective on January 1, 2017.
Under the original rule, gins were required to submit the records from their completed 2016 Form 300A. by July 1, 2017. After the first year, covered establishments must submit the information by March 2 of each year.
When July 1 rolled around, the database was not in place on the OSHA web site, so there was no way to report this information. In the meantime, OSHA delayed the posting requirement of this rule until December 1, 2017. You do not need to post your information from the OSHA 300A until December 1, 2017. If you would like to post it earlier, you are free to do so, but remember that this rule could be further delayed or even eliminated between now and December 1, 2017.
The web site was brought up on August 1, but it was only up for about two weeks, and then was brought back down. Turns out the Homeland Security folks found a security breach in the web site. This was exactly the type of problem we predicted when this rule was originally proposed.
The web site was brought back up about August 25, so we would assume the security problems have been addressed. Click here to view the web site. Please let us know if you have any questions.