Tag: annual reporting

February 29, 2024

OSHA High-Hazard Industry Reporting Requirements

The Occupational Safety and Health Administration (OSHA) has updated its reporting rules for businesses in high-hazard industries. The new OSHA high-hazard industry regulations took effect January 1, 2024, with an annual reporting deadline of March 2.

New Rule

The updated regulations require certain employers to submit more comprehensive injury and illness data to OSHA. This requirement is not entirely new. However, the scope and depth of the information now required is more extensive than previous mandates.

Establishments with 100 or more employees in certain “high-hazard” industries must submit detailed reports from their Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) annually. These submissions are in addition to the already required Form 300A (Summary of Work-Related Injuries and Illnesses).

The forms and additional filing information are available here.

OSHA’s Objectives

The rationale behind the enhanced reporting requirement is multifaceted. First, it aims to arm OSHA with the data necessary to identify workplace hazards more effectively and implement strategies to mitigate them. Second, by making some of this data publicly available, OSHA intends to encourage employers to improve workplace safety proactively, knowing that their injury and illness records may be subject to public scrutiny.

Industries in Focus

The rule targets so-called “high-hazard industries”. This broad category includes many aspects of agriculture, healthcare, manufacturing, construction, and entertainment, among other industries.

Click here for a complete list of affected industries, by NAICS codes.

Again, the changes only affect establishments in the designated businesses with 100 or more employees.

OSHA retained pre-existing rules regarding electronic submission of information from Form 300A from establishments with 20-249 employees in certain high-hazard industries and from establishments with 250 or more employees in industries that must routinely keep OSHA injury and illness records.

Strategic Compliance

For employers subject to this rule, the path to compliance involves several key steps. First, it’s crucial to understand whether your business falls within the scope of the relevant “high-hazard” classification. From there, ensuring that your record-keeping practices are up to the task will be vital. This means not only accurately documenting work-related injuries and illnesses but also being prepared to submit this data in the format and timeframe OSHA requires.

Additionally, employers should view this regulation not just as a compliance challenge but as an opportunity to reassess and strengthen their overall approach to workplace safety. Implementing robust safety protocols and fostering a culture of transparency and accountability can help reduce the risk of injuries and illnesses in the first place.

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October 31, 2023

2022 EEO-1 Component 1 Data Collection

The U.S. Equal Employment Opportunity Commission (EEOC) opened the 2022 EEO-1 Component 1 data collection on October 31, 2023. The deadline for submissions and certifications is set for December 5, 2023.

Understanding the EEO-1 Component 1 Report

The EEO-1 Component 1 report is an obligatory annual data collection exercise for private sector employers with 100 or more employees, as well as federal contractors with 50 or more employees meeting certain criteria. This report requires the submission of workforce demographic data, including data segmented by job category, gender, and race or ethnicity.

New Resources for Filers

In an effort to streamline the data submission process, the EEOC’s Office of Enterprise Data and Analytics (OEDA) has launched a new EEO-1 Component 1 Instruction Booklet for the 2022 data collection period. This booklet consolidates various support materials, such as frequently asked questions and fact sheets, into a single resource. It also provides additional information to clarify eligibility and reporting requirements.

Enhanced Filing Process

The EEOC announced that it has enhanced the filing process by introducing self-service options and an online Filer Support Team Message Center within the EEO-1 Component 1 Online Filing System (OFS). This platform enables filers to submit requests for assistance, update requests with new information, terminate requests, and track the status of requests, thereby simplifying the filing process.

Additional EEOC Data Collections

The EEOC has also opened the 2023 EEO-4 state and local government data collection, which is also due on December 5, 2023. This mandatory data collection requires all state and local governments with 100 or more employees to submit demographic workforce data every two years. A new EEO-4 Instruction Booklet is now available to aid in this process.

Employer Compliance

All employers must determine whether they are required to file EEO data. If so, you should make sure you have the necessary data prepared in time to meet the filing deadlines. Hopefully, the new guidance resources from the EEOC will make it easier for companies to comply with the reporting process.

February 1, 2019

Delayed Filing for 2018 EEO-1

The U.S. Equal Employment Opportunity Commission (EEOC) has postponed the filing period for 2018 EEO-1 surveys. Employers usually must file these annual reports by March 31st. However, this year’s deadline will be May 31, 2019, as a result of the recent federal government shutdown.

Who Must File a 2018 EEO-1?

Private employers with 100+ employees must annually report employee data on race, ethnicity, and gender by occupational category.

Many federal contractors with less than 100 but more than 50 employees also must file these EEO-1 reports.

EEO-1 Data

The EEO-1 survey requires covered employers to identify the number of employees they have in various job categories based on several demographic groups.

The EEO-1 job categories are:

Executive/Senior Level Officials and Managers
First/Mid-Level Officials and Managers
Professionals
Technicians
Sales Workers
Administrative Support Workers
Craft Workers
Operatives
Laborers and Helpers
Service Workers

Within these job categories, employers must provide the number of employees based on sex and race/ethnicity from among these options:

Hispanic or Latino
White
Black or African American
Native Hawaiian or Pacific Islander
Asian
Native American or Alaska Native
Two or more races

Employers must attempt to allow employees to self-identify among these groups. If an employee declines to do so, then the employer can rely on existing employment records or observer (e.g., manager) identification to complete the survey.

The EEO-1 is a snapshot report as of a single pay period in October, November, or December. Thus, it does not necessarily reflect all individuals who worked for the company during the survey year.

Why the Delay?

The EEOC has not finalized details and instructions for the 2018 EEO-1 reports. It expects to open filing for employers in early March 2019.

For updates on the 2018 EEO-1, visit the EEOC’s website.

Not Unprecedented

EEO-1 filing was also delayed last year.

Toward the end of the Obama administration, the EEOC planned to modify the EEO-1 report to include wage and hours data beginning with reports of 2017 data. The Trump administration, however, rejected that expansion.

Though it’s not clear whether that situation alone prompted the move, the EEOC postponed the filing deadline to June 1, 2018, for 2017 data. So, barring a further postponement this year, employers have one fewer day (albeit a Saturday) to submit the 2018 EEO-1 surveys.

What Should You Do Now?

If you’re not already sure, check to determine whether your company must file a 2018 EEO-1. If you will be filing for the first time, make sure you know what data to use. You might also need to obtain employee self-identification of ethnicity. Then check back with the EEOC in early March to confirm the procedure for filing this year.

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