The Occupational Safety and Health Administration’s (OSHA) revised Final Rule on requirements for electronic submission of workplace injury and illness information to OSHA becomes effective on January 1, 2024. Under the revised Final Rule, some of the current requirements remain in place and a new requirement has been added which may impact establishments with 100 or more employees. Details of the revised Final Rule are as follows:
- Establishments with 100 or more employees in certain designated industries are required to electronically submit information to OSHA from their OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 301 (Injury and Illness Incident Report) and 300A (Summary of Work-Related Injuries and Illnesses) annually.
- Establishments with 20 to 249 employees in certain industries will continue to be required to electronically submit information from their OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) annually.
- Establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation, (i.e., those not partially exempt from OSHA’s recordkeeping requirement) will also continue to be required to electronically submit information from their Form 300A (Summary of Work-Related Injuries and Illnesses) annually.
The deadline for timely submission of the previous year’s injury and illness data is March 2 of each year.
Of note, the requirements also apply to establishments covered by states with their own occupational safety and health programs (i.e., State Plans).
How to Submit the Data
The data must be submitted using OSHA’s secure website (Injury Tracking Application (ITA)). The ITA will begin accepting 2023 injury and illness data on January 2, 2024. OSHA offers three options for injury and illness data submissions which include:
- Manually entering data;
- Uploading a CSV file to add multiple establishments at the same time; or
- Transmitting data electronically via an API (application programming interface).
What Happens with the Data Submissions
OSHA intends to publicly publish some of the data collected from the submissions on its website to allow employers, employees, potential employees, employee representatives, current and potential customers, researchers, and the general public to use information about a company’s workplace safety and health record.
Next Steps
Employers should visit OSHA’s website to determine if they are subject to any of OSHA’s reporting requirements and ensure that if applicable, electronic submissions of any applicable forms (Forms 300, 301, and/or 300A) are submitted by March 2, 2024. Employers may use OSHA’s ITA Coverage Application tool to determine if they are subject to OSHA’s recordkeeping requirements.
For additional information on these requirements, employers may visit the OSHA website by clicking here.
