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72 Security Dealer & Integrator / www.SecurityInfoWatch.com October 2016 We anticipate that the new inter- pretation will result in additional unfounded retaliation citations. In its explanation to the Final Rule, the agency also posits that employer policies requiring an employee to "immediately" report an injury may also be retaliatory. OSHA believes that immediate-reporting policies will chill employees from reporting slow-devel- oping or chronic injuries or illnesses, such as musculoskeletal disorders. According to OSHA, to be reason- able, a policy must allow for report- ing within a "reasonable" time aer the employee realized that he or she had suffered a work-related injury, rather than requiring that the injury be reported immediately following the occurrence of an injury. Of course, OSHA fails to define what it considers to be "reasonable." By supporting Mission 500, you'll join the legions of security professionals who are already contributing their time and resources to help children in need across the US. Your contributions provide food, education, and healthcare where little or none is available. Please make an investment in our collective future. Together with Mission 500 we can make a difference. Find out how you can help by calling Jeff Eichenlaub at 631.219.8728 or emailing him at jeichenlaub@mission500.org. Mission500.org together we can... together we can... educate inspire nourish heal Request information: www.SecurityInfoWatch.com/10487869 We anticipate that this will also lead to significant mischief related to worker compensation claims and whether injuries are truly work-related. Electronic Data Submission Unlike the anti-retaliation provisions in the new Rule, OSHA spends minimal time interpreting Electronic Submission requirements, which are supposedly the real purpose behind the new rule. e Electronic Submission portion of the Final Rule requires individual employer establishments with 250 or more employees to submit informa- tion electronically from their 2016 Form 300A by July 1, 2017. ese same employers will be required to sub- mit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereaer, the information must be submitted by March 2. For the next three years, estab- lishments with 20 to 249 employ- ees operating in OSHA-designated "high-hazard industries" must submit Form 300A by July 1 of the following year. Beginning in 2019 and every year thereaer, the information must be submitted by March 2. OSHA intends to post this data on a public website, which will be accessible by competitors, contractors, employees, and employee representatives. ■ » James L. Curtis is a partner at the law firm Seyfarth Shaw LLP, concentrating his practice in environmental, safety and health law. He can be reached at (312) 460-5815 or via email at jcurtis@seyfarth.com. Your Business