OSHA’s new online reporting rule becomes effective on January 1, 2017, but the reporting requirements are to be phased in over 2 years. The new rule requires that certain employers electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. OSHA has indicated that some of the data will be posted to the OSHA website.
Although automobile dealers are still required to record and post injury and illness data on site at the dealership, as for car dealership with less than 250 employees at a single establishment, the online reporting requirements do not apply. For those car dealerships with more than 250 employees at a single location, they must electronically submit their 2016 reporting information on or before July 1, 2017 and their 2017 information on or before July 1, 2018; thereafter, the deadline will be March 2nd of every successive year.
In addition to the online reporting requirements, beginning November 1, 2016[1], the new rule prohibits discouragement of reporting injury or illness by employees and requires employers to keep employees informed of their right to report in a retaliation free environment and to maintain reasonable procedures for reporting injuries and illnesses in a way that is undeterred by the employer.
If you would like additional information, please do not hesitate to contact a member of the Dealer Practice Group at 248-645-9300 or by email:
- Charles A. LeFevre, Chair, [email protected]
- Lawrence F. Raniszeski, [email protected]
- Michael J. O’Shaughnessy, [email protected]
- Eric R. Bowden, [email protected]
- Alycia Pallach Wesley, [email protected]
- Coriann Gastol, [email protected]
———————————–
[1] Although technically this became effective on August 10, 2016, OSHA delayed enforcement until November 1, 2016.