Many employers with more than 10 employees – including electrical contractors around the country – are required by the Occupational Safety and Health Administration to keep a record of serious work-related injuries and illnesses. Minor injuries requiring first aid only do not need to be recorded.
As part of a new reporting rule issued by OSHA, all employers will be required to submit their 300A Summary electronically beginning on Jan. 1, 2017.
Companies with 250 or more employees must start providing additional information in 2018, including the 300A Summary and the 300 log form and all 301 or incident reports that have been purged of employee and physicians names and addresses.
OSHA has given all employers until July 1, 2017 to submit the 300A electronically via its web portal for employers of 20-249 for the calendar year 2016 and July 1, 2018 for calendar year 2017.
Regarding post-incident testing, the National Electrical Contractors Association’s Drug Free Work Place programs that are part of its collective bargaining agreements and in writing, communicated to all parties and managed consistently, do not fall into the category of discriminatory according to OSHA requirements.
OSHA does not prohibit post-incident testing and incentive programs as long as they do not discourage reporting of injuries in any way. If a contractor, for instance, only did post-incident testing after an incident or accident, that could be deemed discriminatory and possibly discourage reporting.
A Drug Free Work Place program that has pre-employment testing, random testing and reasonable suspicion testing along with post incident would be a program that does not discriminate against an employee simply for being involved in an accident or incident, it would be a total program that would discourage drug use in the workplace and protect all employees from these exposures.
An upcoming free webinar, Everything You Need to Know About OSHA's New Recordkeeping Rule, will be held on Jan. 5 at 11 a.m. EST. Registration is required, so visit NECAEvents.WebEx.com to register.
For additional information on OSHA’s webpage on the new reporting rule, go to https://www.osha.gov/recordkeeping/finalrule/index.html.