OSHA Reminder:  California Employers Required to Submit Form 300A by December 31 2018.

12.21.2018

On October 18, 2018, the California Department of Industrial Relations, Division of Occupational Safety and Health ("the Division") issued an amended notice of proposed emergency action, proposing to adopt emergency amendments to Sections 14300.35 and 14300.41 of Title 8 of the California Code of Regulations. These proposed amendments would require designated employers in California to submit electronically certain occupational injury and illness information to the federal Occupational Safety and Health Administration ("OSHA"), with the first submission due by December 31, 2018. The proposed regulatory language and Finding of Emergency can be found on the Division’s website.

On November 1, 2018, the Office of Administrative Law approved the emergency action.   This means that certain required employers in California must submit Form 300A covering calendar year 2017 by December 31, 2018 if it has not already been submitted.  Who needs to comply?

  • Employers with 250 or more employees per establishment must electronically submit their 2017 Cal/OSHA 300A forms, unless exempted by Title 8 California Code of Regulations Section 14300.2.
  • Employers with 20 to 249 employees in the specific industries listed in Appendix H of the emergency regulations. Construction is one of the designated industries.

These employers should follow the instructions posted at federal OSHA’s Injury Tracking Application (ITA) website. 

Both categories must be submitted on or before December 31, 2018, and then by March 2, 2019 for the 2018 Cal/OSHA 300A form.  

If you have an questions or comments regarding this update, contact Jonathan S. Vick at 562-653-3200.

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