California El Camino Real Association of Occupational Health Nurses

Cal-OSHA has posted emergency regulations about electronic filing of the OSHA log by 12/31/18

Posted 4 months ago by Lori Wolfe

Log 300 / Form 301 Recording and Reporting Occupational Injuries and Illnesses, with Anti-Discrimination Provisions

Effective January 1, 2017, employers in states regulated by federal OSHA were required to electronically submit Log 300 records of injuries and illnesses. The electronic reporting requirements, along with the incorporation of an existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses, were added to federal OSHA's recording and reporting regulations found in the Code of Federal Regulations, title 29, part 1904.

On April 30, 2018, federal OSHA posted a "trade release" requiring all affected employers to submit injury and illness data in the federal OSHA Injury Tracking Application (ITA) online portal, even if the employer is covered by a state plan that has not completed adoption of their own state rule:

Therefore, even though California has not yet adopted its own state rule, affected employers are advised to comply with federal OSHA's directive to provide Form 300A data covering calendar year 2017. Federal OSHA is requiring affected employers to submit their data by July 1, 2018. For specific instructions, go to federal OSHA's ITA website.

On July 27, 2018, federal OSHA posted a "trade release” that it proposes to amend its recordkeeping regulation by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injury and Illness Incident Report). These establishments will continue to be required to submit information from their Form 300A (Summary of Work-Related Injuries and Illnesses). For additional information and links, go to federal OSHA’s trade release:

On October 10, 2018, the Department of Industrial Relations, Division of Occupational Safety and Health ("the Division") provided 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 at the following address:

October 2018