White Paper

OSHA Finalizes Rule Rescinding Electronic Submission of Certain Injury and Illness Records


How does this rule impact employer's obligations to submit annual OSHA forms?

The Occupational Safety and Health Administration completed a rule that declares null and void the obligation of establishments consisting of more than 250 employees to submit OSHA Form 300 and Form 301 electronically to OSHA on an annual basis. This white paper reviews the new final rule which eliminates a requirement that came about when OSHA released its 2016 electronic reporting rule.



Mark N. Duvall

Beveridge & Diamond, P.C.

Mark Duvall has over two decades of experience working in-house at large chemical companies. His focus at Beveridge & Diamond, P.C. has been on product regulation at the federal, state, and international levels across a wide range of programs, and occupational safety and health.

He heads the Firm’s Toxic and Harmful Substances/Toxic Substances Control Act practice. His experience under TSCA includes enforcement actions, counseling, rulemaking, advocacy, and legislative actions. Since the enactment of TSCA amendments in 2016, he has been heavily involved in advocacy, compliance activity, and litigation arising from EPA's implementation of these amendments. He also works with foreign counterparts to TSCA, including REACH and CEPA.

He also heads the Firm’s Occupational Safety and Health practice. He has extensive experience with OSHA and state OSHA inspections, enforcement litigation, compliance counseling, advocacy, and rulemaking, with particular emphasis on process safety. He has counseled clients on the EPA risk management program requirements under Section 112(r) of the Clean Air Act and state worker protection programs, and on inspections by the Chemical Safety and Health Investigation Board.

Jayni A. Lanham

Beveridge & Diamond, P.C.

Jayni Lanham’s practice includes litigation and regulatory counseling on federal and state environmental, health, and safety laws and related common law matters. Jayni’s litigation practice involves pre-trial motions practice, complex discovery, and the development of effective technical defenses. In addition to her litigation practice, Jayni counsels clients on a variety of environmental, health, and safety programs. A leader of Beveridge & Diamond’s Occupational Safety and Health group, Jayni advises clients on compliance and enforcement issues related to the Occupational Safety and Health Act (OSHA) and its state equivalents.

Michael F. Vitris

Beveridge & Diamond PC

Michael F. Vitris is an associate in the Austin, TX office of Beveridge & Diamond PC. Mr. Vitris maintains a diverse litigation and regulatory practice across a variety of environmental media. Prior to joining Beveridge & Diamond, he represented the Executive Director in enforcement litigation and provided legal counsel to program areas as an attorney at the Texas Commission on Environmental Quality (TCEQ).

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