Cal/OSHA approved an emergency regulation on November 1, 2018 that requires covered employers to submit their Form 300A (Summary of Work-Related Injuries and Illnesses) data covering calendar year 2017 to the federal OSHA Injury Tracking Application (ITA) online portal by December 31, 2018.

Earlier in 2018, federal OSHA began requiring covered employers to electronically submit certain records of occupational injuries and illnesses. The motion picture industry is exempt from federal OSHA, so the industry did not need to take any action with respect to this new reporting requirement.

However, the motion picture industry is not exempt from Cal/OSHA. With the November 1 emergency regulation, Cal/OSHA makes the federal OSHA’s e-reporting requirement applicable to the motion picture industry.

Who must electronically submit?

Establishments with 250 or more employees that are currently required to keep Cal/OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.

Reporting requirements apply at an establishment level, not to the employer as a whole. An establishment is a single physical location where business is conducted or where services or industrial operations are performed. Establishments that meet either of the following criteria must submit injury and illness data:
The establishment employed, at any time during the previous calendar year, 250 or more employees, regardless of the establishment’s industry and rate of occupational injury or illness; or

The establishment employed, at any time during the previous calendar year, at least 20 but less than 250 employees, and the establishment is classified in an industry listed in Appendix H of Cal/OSHA as an industry with a historically high rate of occupational injury or illness.
The motion picture and entertainment industries are not listed in Appendix H. Therefore, only motion picture employers with 250 or more employees during calendar year 2017 need to submit injury and illness data.

What must be submitted?

Covered establishments must electronically submit information from their 2017 OSHA Form 300A – Summary of Work-Related Injuries and Illnesses. OSHA is not currently accepting Form 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injury and Illness Incident Report).

When is it due?

In 2018, covered establishments must submit information from their completed 2017 Form 300A by December 31, 2018. Beginning in 2019 and every year thereafter, covered establishments must be prepared to submit their completed 2018 Form 300A by March 2, 2019.

How must it be submitted?

Your 2017 Form 300A should be submitted through OSHA’s Injury Tracking Application (ITA), found on OSHA’s website, www.osha.gov/injuryreporting/ita/.

Please note that EP is providing this information as a courtesy to our clients. Federal and state OSHA reporting is the responsibility of the production. For more information on the federal OSHA electronic reporting requirements, please review the Frequently Asked Questions published on OSHA’s website, available here. If you have additional questions or concerns, please contact Richard Morgan, Senior Manager, Risk Solutions, at 818.480.4252 or rmorgan@ep.com.