Not sure why I’m feeling blindsided by this news http://www.jdsupra.com/legalnews/moving-workplace-injury-and-safety-34458/. I was just reading the most recent AOHP e-bytes and noticed the article referring to electronically submitting injury information. I knew we were expecting this for incidents of work-place violence but did not understand the potential for our 300 logs.

Does anyone have a plan in place or has OSHA even determined the means in which to report?

Be well,

Angeli

 

Angeli Mancuso, RN, COHN-S/CM

Employee Health & Safety Manager

Ph: 805.569.7866/Internal Ext. 57866

Fax: 805.569.8271

a1mancus@sbch.org

www.cottagehealthsystem.org

The finalized OSHA requirement mandates that health care employers with 250 or more employees must submit 2016's Form 300A (Summary of Work Related Injuries and Illnesses) data by July 1, 2017. It also mandates that data for 2017 incidents recordable on Form 300A, Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) must be submitted electronically by July 1, 2018. Other employers (depending on their size and the nature of their business) must also submit these reports electronically.

MediTrax -- like other occupational health software applications -- has been able to produce Form 300A, Form 300, and Form 301 reports for many years. These reports can all be printed to PDF electronic documents using the CutePDF printer driver or any printer driver capable of generating PDF documents. However, what OSHA has NOT made clear is

• where the "electronic reports" must be sent (the language of the current regulation is that the reports must be sent "to OSHA or OSHA’s designee"), and
• the specific format for submitting the information (which we can only hope will not require manual data entry on an OSHA website).
  

The regulation also provides in §1904.41(b)(6) that "OSHA will provide a secure Web site for the electronic submission of information. The website will include web forms for direct data entry and instructions for other means of submission (e.g. file uploads)," but the updated regulation seems to have omitted the URL of that website as well as any indication of their definition of "file uploads". I suspect that neither the website nor the instructions actually exist yet. I have contacted OSHA's national and regional offices, but nobody seems to have a clue as to how the regulation will actually be implemented. 

--
Joe Fanucchi MD FACOEM
President and Medical Director
MediTrax / OHS, Inc.
o:925-820-7758
c:925-368-3367

MediTrax software: Everything you need, at a fraction of the cost!