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Prepare Clients Now for Significant OSHA Recordkeeping Changes

OSHA has proposed critical changes to its annual electronic submission rules—prepare your clients now!
Prepare Clients Now for Significant OSHA Recordkeeping Changes

As we’ve seen in recent years, the presidential administration sets the tone for OSHA, and the OSHA electronic recordkeeping rule has changed a few times since its inception in 2016. Here’s a quick summary:

    1. In 2016, OSHA enacted the e-recordkeeping rule under the Obama administration, requiring for the first time that many employers electronically submit OSHA data each year.
    2. In 2019, OSHA made changes under the Trump administration, reducing the reporting requirements for the largest employers and also adding the requirement to include the Employer Identification Number (EIN) when submitting data.
    3. In 2022, OSHA proposed another update under President Biden, which would make reporting requirements even more robust than the original rule in 2016. Though this proposed rule has not been finalized, many experts expect that it will be in 2023, likely in effect for the March 2, 2024 reporting deadline.

It’s unsurprising that many employers are confused (or even unaware) of the current requirements given all this activity and proposed changes. As an agent, this offers a perfect opportunity to show your value as an agent, supporting your existing clients while also enhancing your prospecting efforts by calling the incumbent into question.

Read on for details about where the rule stands now, what the proposed updates are, and how you can strategically use that information to strengthen and grow your book.


The OSHA electronic recordkeeping rule specifics

Let’s start by digging into the details below.


There are two key points to keep in mind.

    1. All employers covered under the current rule (last amended in 2019), must submit their 2022 OSHA data by March 2, 2023 based on how the rule is currently written.
    2. The 2022 proposed changes are likely to be enacted in 2023, which means you should educate and prepare your clients and prospects now, so their 2023 OSHA records are in good shape for the following reporting deadline in 2024.

Deliver enormous value to your clients

This is your time to shine as an agent. For your existing clients, if you haven’t already, have a conversation about the March 2, 2023 deadline (if they must comply based on the requirements above). Offer to audit your clients’ OSHA forms to eliminate any errors before the submission season.

Once your client feels comfortable that they are ready to comply in 2023, follow up with a heads-up about the changes potentially coming in 2023 for the following reporting period. Again, talk to them about best practices and common errors to watch out for, and offer to audit regularly next year to help prepare them.

If you want to make OSHA recordkeeping even easier for your clients, give them a free subscription to They simply enter the incident data once and the program automatically populates all three OSHA forms and submits the data directly to OSHA per the recordkeeping rule.


Quickly earn prospects’ attention

Imagine sending these branded resources to your top prospects, offering to audit their OSHA logs, and helping them prepare to comply with the deadline. You’ll put instant doubt into any prospect’s mind if their own agent hasn’t provided the same support—or even mentioned the compliance deadline.

By the way, is also a great prospecting tool. It’s an opportunity to provide free value without the pressure of an AOR, which actually sets you up as the logical agent of choice.

Questions about or OSHA recordkeeping in general? Contact us - we’d love to chat!

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