As we previously reported to you in 2015, OSHA and MIOSHA began requiring auto dealers, which were previously exempt from OSHA record keeping requirements, to begin keeping a record of occupational injuries and illnesses using OSHA Log 300.
Beginning July 1, 2017, auto dealers will now be required to begin electronically submitting information to OSHA. Dealers with 20-249 employees will be required to electronically submit information from OSHA Form 300A. Dealers with individual stores that employ 250 or more employees (the threshold number of employees is determined by store not by corporate affiliations) will be required to begin electronically submitting information from the following OSHA Forms:
- 300 – Log of Work-Related Injuries and Illnesses
- 300A – Summary of Work-Related Injuries and Illnesses
- 301 – Injury and Illness Incident Report
The following is an outline of the required forms to be submitted online and the dates of submission for each of the next three years.
| Submission Year | 250 or More Employees | 20-249 Employees | Deadline |
|---|---|---|---|
| 2017 (2016 calendar year) | Form 300A | Form 300A | July 1, 2017 |
| 2018 (2017 calendar year) | Forms 300A, 300, 301 | Form 300A | July 1, 2018 |
| 2019 (2018 calendar year) | Forms 300A, 300, 301 | Form 300A | March 2, 2019 |
Forms 300, 300A and 301 are attached for your reference (click here for forms) and can also be found on OSHA’s website at: https://www.osha.gov/recordkeeping/new-osha300form1-1-04-FormsOnly.pdf.
At this time, OSHA does not have its online reporting portal established; but dealers should already be compiling the information for completion of the forms, as dealers have been included in the record keeping requirements since 2015. Once the online submission information is made available by OSHA, we will convey the details to you. The electronic submission requirements do not change your obligation to complete and retain injury and illness records.
Information is available from OSHA regarding this topic at: https://www.osha.gov/injuryreporting.
If you have any questions about the foregoing or if you need guidance on what types of injuries or illnesses are recordable under OSHA, please feel free to contact a member of our Dealer Practice Group at 248-645-9300 or by email.
Chuck 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]
Nicholas J. Ranke – [email protected]
