2016 Federal Poster Update

Updated Wednesday, July 6, 2016 – see Customer Impact section for poster shipment timelines.

Due to the Department of Labor’s recent release of the OSHA Injury and Illness Reporting final rule, GovDocs is initiating a Federal Poster update, which will be sent to applicable locations starting in June.

OSHA Injury and Illness Reporting Final Rule: Background and Details

• The Department of Labor officially released a long-awaited OSHA Injury and Illness Reporting final rule May 12, 2016, which among other things, updates the requirements on how employers inform employees on reporting work-related injuries and illnesses, as well as clarifies their rights to access injury and illness records.
• Specifically, two sections were amended to ensure employees know and understand their existing right to report work-related injuries and illnesses.  As such, employers are required to inform their employees of these rights, along with their rights to be free from retaliation.
• The OSHA Injury and Illness Reporting final rule doesn’t specify how employers are required to provide this notice to employees, other than “an employer may inform the employees in any way that the employer sees fit.” However, it does state employers will meet this requirement by posting the OSHA Job Safety and Health – It’s the Law (LFD02) workers’ rights posting, dated May 2015 or later.

Final Rule Effective Dates

• Employers are required to provide notice to employees effective August 10, 2016.
• The reporting rule is effective as of January 1, 2017.

GovDocs’ Response 

• We interpret the OSHA Injury and Illness Reporting final rule to mean the Department of Labor believes employers will meet this notice requirement by ensuring the OSHA Job Safety and Health – It’s the Law posting is updated and posted in all locations.
• The OSHA Job Safety and Health – It’s the Law posting was last updated May 2015, when GovDocs subsequently updated all of our Federal products according to our standard processes. It was not required for employers to display the new version.
• Although the Department of Labor has not issued this as a required update, GovDocs believes our customers will want to use this May 2015 posting as the primary method of notification to employees.

Customer Impact (as of July 6)

Federal-on-One Poster Customers:

• If your Federal-on-One poster is dated May 2015 or later, the poster meets the final rule’s requirements.
• If not, we’re in the process of shipping updated Federal All-on-One posters to locations with a GovDocs Update subscription. Based on our records, we know which of your locations are affected.
• Status: Shipments will be completed by July 15. To monitor your locations’ shipment status and tracking details, log into the GovDocs Dashboard.

State and Federal Combined Poster Customers:

• 28 states and Puerto Rico have received updated State and Federal Combined posters – which include the OSHA Job Safety and Health – It’s the Law posting – since May 2015 and, therefore meet the final rule’s requirements.
• Locations with a GovDocs Update subscription in the remaining states should have received an updated State and Federal Combined poster. Based on our records, we know which of your locations were affected.
• Status: Shipments completed June 10. To monitor your locations’ shipment status and tracking details, log into the GovDocs Dashboard.

Electronic Customers:

• Electronic Update: Download the OSHA Job Safety and Health – It’s the Law posting here.
• Intranet Poster Program: The file is available, as of May 2015.