OSHA and PERRP recordkeeping

The end of year has come and gone and that means your OSHA and PERRP Recordkeeping logs, summary and online reporting are due.  You should have already completed your OSHA or PERRP Logs and submitted your PERRP Summary Online, as these deadlines have already passed.   Here is a reminder of the due dates for recordkeeping:

• OSHA and PERRP Summary forms were due to be posted by February 1^st.
• The PERRP online reporting was due February 1^st.
• The OSHA online reporting will be due March 2^nd.

Even if you have not completed your logs or online reporting, it is still a good idea to get these completed as soon as possible.  Both OSHA and PERRP recommend you post and submit your data even if you are past the due dates – remember better late than never!  If you are unsure whether you need to complete the logs or online reporting, you will first need to determine if you are required.

Exemptions

OSHA - There are two exemptions from keeping the OSHA 300 Log.

• Companies with 10 or fewer employees at all times during the calendar year. The only exception to this is if you are specifically requested by OSHA, the Bureau of Labor Statistics (BLS) or another agency to keep a log.  If you receive a request, do not ignore it.
• The other exemption is for establishments classified in certain low-hazard industries. You will need your NAICS number and check it against the list of “Partially Exempt Industries” at:  https://www.osha.gov/recordkeeping/presentations/exempttable. 

PERRP - There are no exemptions for public employers for keeping and maintaining the PERRP Log.  All public employers are required to keep the Log.

Recordkeeping logs and summary form

OSHA - If you are required to keep the log, download the Recordkeeping Forms and instructions by clicking on the link: https://www.osha.gov/sites/default/files/OSHA-RK-Forms-Package.pdf.  

PERRP – Download the recordkeeping instructions by clicking on the link: https://www.bwc.ohio.gov/downloads/blankpdf/PERRPrecordkeepingforms.pdf.  The log can be downloaded from:  https://www.bwc.ohio.gov/downloads/blankpdf//perrprecordkeepingpackage.xls.

When you complete your PERRP or OSHA log be sure to have the summary form signed and posted in a conspicuous place for employees to see.  Summaries must be posted from February 1^st through April 30^th.

*Remember only post the PERRP 300AP Summary or the OSHA 300A Summary and not the injury log.*

Online submission

The final step in the process is to determine if you must file online. 

OSHA - To determine if your organization is required to do so, review the information on OSHA’s Injury Tracking Application (ITA) by going to: https://www.osha.gov/injuryreporting/ and clicking on the “Who is covered by this reporting requirement?” box towards the bottom of the page.  If your establishment is required to submit online, then you must create a secure account at: login.gov.   Once you have successfully set up an account, then you can submit your OSHA 300A Summary information.  The online submission is a fairly straight forward process, just be sure to have your NAICS number, average number of employees and total work hours entered on your OSHA 300A Summary report.

Another way to determine if you organization is required to do so, is enter your facility information at the following link https://www.osha.gov/itareportapp.  You will need to supply the following information:

• “State” your facility is located.
• “Peak Employment from the previous year” – be sure include temps and seasonal workers.
• “Is the establishment a government facility” and
• Your “NAICS Code”.

Once the information is entered, hit the “Submit” button and it will identify if your facility needs to submit online.

PERRP –All public employers are required to submit to the BWC except those with five or fewer employees and that also have had no recordable injuries in the calendar year.  PERRP 300AP Summary form information is submitted through the Ohio BWC link found here: https://www.bwc.ohio.gov/employer/forms/InjuryIllnessSummary/default.aspx.

If you need further assistance or have questions, please contact Andy Sawan Andrew.Sawan@sedgwick.com, 330.819.4728 or Craig Lanken Craig.Lanken@sedgwick.com, 330.472.1656.