[MCOH-EH] Electronic reporting of workplace injuries

[Dr Joe Fanucchi]

On 5/16/2016 12:42 PM, Angeli Mancuso wrote:
>
> 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 at sbch.org <mailto:a1mancus at sbch.org>
>
> www.cottagehealthsystem.org <http://www.cottagehealthsystem.org/>
>
> Description: EMAIL SIG- CH
>
------------------------------------------------------------------------
Greetings colleagues,

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.

Regards,

Joe Fanucchi

-- 
*Joe Fanucchi MD FACOEM*
President and Medical Director
MediTrax / OHS, Inc. <http://www.meditrax.com/>
o:925-820-7758
c:925-368-3367
<http://www.meditrax.com/>
/MediTrax software: Everything you need, at a fraction of the cost!/
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