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Proposed OSHA Rule Change Could Expand Reporting Requirements for Senior Living, Skilled Nursing Providers

Proposed amendments to federal occupational injury and illness recordkeeping regulations could require senior living providers, skilled nursing operators, and other employers in “high-hazard industries” to submit additional documentation of each injury or illness reported.

Currently, small and large senior living and skilled nursing operators must annually submit the Occupational Safety and Health Administration (OSHA) Form 300A summary of all work-related injuries and illnesses recorded in their OSHA 300 logs. Under the proposed regulation change, certain senior living and skilled nursing operators would also be required to electronically submit their OSHA 300 logs and every OSHA Form 301 for each recordable injury or illness entered in the logs.

Specifically, the proposed rule would:

  • Require establishments with 100 or more employees in certain high-hazard industries to electronically submit information from their OSHA Forms 300, 300A, and 301 once per year.
  • Update the classification system used to determine the list of industries covered by the electronic submission requirement.
  • Maintain the current requirement for establishments of 20 or more employees to submit their OSHA Form 300A annually.
  • Remove the requirement for employers of 250 or more employees that are not in a designated industry to submit their OSHA Form 300A annually.
  • Require establishments to include their company name when making electronic submissions to OSHA.

More information is available in the Federal Register notice. Members may also submit comments online until May 31st using Docket No. OSHA-2021-0006 on the Federal eRulemaking Portal.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828