November 2018 California Regulatory Updates

by Camille Bradbury on November 12, 2018

CALIFORNIA UPDATE

Heads Up! Emergency Recordkeeping Regulation: Submit 300A Forms by December 31, 2018
Effective Date: December 31, 2018

As part of Assembly Bill 2334, California’s Division of Occupational Safety and Health (Cal/OSHA) released Emergency Regulatory Action on Recording and Reporting of Occupational Injuries and Illnesses.

This means that even if federal OSHA makes electronic reporting optional for injury and illness information, qualifying California employers will still need to submit it. Under AB 2334, if federal OSHA eliminates electronic reporting requirements, California will create an advisory committee to determine how employers will file their information with the state.

Who Reports?

  • If you had 250+ employees at any single establishment/location of yours at any point in 2017, you need to electronically file your 2017 Cal/OSHA 300A form by the end of 2018. Submit 2018 information by March 2, 2019. (There are exempt industries in this employee size bracket, but KPA clients are not among them.)
  • If you had 20-249 employees at any point in 2018 AND you’re in one of 66 qualifying industries, you need to electronically file. Note: Auto dealerships with 20-249 employees do not have to electronically file.
  • All employers, regardless of employee size, must report to federal OSHA immediately whenever a serious workplace injury (inpatient hospitalization, amputation, loss of an eye, or death) occurs. For more information, see Cal/OSHA’s Report a Work-Related Accident.

Considerations

  • Qualifying California employers still must submit 2017 300A Forms to federal OSHA by December 31, 2018. Submit your 2018 300A Forms by March 2, 2019.
  • If you’re a KPA EHS client, you can pull a report from myKPAonline and submit the OSHA 300A form using federal OSHA’s online Injury Tracking Application.
  • If you’re in an exempt industry and Cal/OSHA requests it, you may still need to electronically submit your OSHA 300A form.
Share this post:
Camille BradburyNovember 2018 California Regulatory Updates