In an effort to ensure compliance, an emergency Record Keeping Regulation has been issued to bring Cal/OSHA in line with Fed-OSHA requirements.

Cal/OSHA announced that the required 300A Summary of Work-Related Injuries online filing is now "official" and California employers must comply by December 31, 2018 for 2017 Report, if not already done.

The Division of Occupational Safety and Health (DOSH) has published an Emergency Regulation requiring all employers with 250+ employees to electronically submit their annual 300A Summary of Work-Related Injuries. Employers in selected industries - with between 20 - 249 employees also must electronically submit the 300A. 

The original DOSH original version of the regulation was issued on October 10, but it appears few, if any stakeholders were aware of it. DOSH has now reissued the emergency regulation.

Stakeholders attending an October Cal-OSHA Standards Board meeting were surprised when a DOSH official announced the regulatory move. Confusing language made it appear that employers were required to electronically submit their 2018 300A data by December 31, 2018, which would be impossible. The DOSH Legal Unit revised that issue stating that it is referring to 300A summaries for 2017.

On October 23, 2018, DOSH will officially submit the Emergency Action to the Office of Administrative Law (OAL). The OAL will then provide stakeholders five days to comment. Also, an Emergency Regulation will appear on the OAL website, oal.ca.gov. OAL then has 10 days to review the action after the comment period and if it passes muster, it will take effect after that period.

Guest post by Don Dressler. Combined partner with CalWorkSafety to help clients comply with Cal/OSHA regulations every by helping them prevent work accidents and saves on workers' compensation costs.For more information send an email to: inquiry@combinedca.com or CONTACT US