Update to electronic submission requirements for employers
As of January 1, all establishments with 100 or more employees at any time during the previous calendar year that are in one of the high-hazard industries listed below are required to submit case-specific information from their OSHA 300 and 301 forms, as well as their OSHA Form 300A annual summary.
Establishments with 20 to 249 employees in certain industries, and all establishments with 250 or more employees that are required to keep OSHA 300 records, will continue to be required to electronically submit information from their OSHA 300A annual summary to OSHA once a year.
Employers can access the Injury Tracking Application (ITA) by March 2 each year to submit the required information from the prior calendar year to OSHA.
Currently, employers haven't been submitting information from their OSHA 300 and 301 forms annually. Two groups of establishments were required to submit information from their OSHA 300A annual summary to OSHA once a year:
- Establishments with 250 or more employees in industries required to routinely keep OSHA injury and illness records.
- Establishments with 20-249 employees in certain designated industries.
Key takeaways
- This update applies to employers who fall under Federal OSHA, as well as approved state plans.
- OSHA plans to publish some of the data collected on its website for the public to use to make informed decisions about a company's workplace safety and health.
- OSHA will identify and remove information that could reasonably be expected to identify individuals directly, such as individuals' names and contact information.
- Establishments will be required to include their legal company name when making electronic submissions to OSHA.
- Many employers use an insurance form such as a worker's compensation First Report of Injury or Illness form instead of the OSHA 301. It's important that the form has the same information, is readable and is completed using the same instructions as the OSHA form it replaces, or supplements the insurance form by including any additional information required by OSHA.
- In addition to ensuring the OSHA forms are accurately completed, it will be increasingly important to strategize on how to minimize instances of recordable injury and illnesses in the workplace. With the increased visibility to OSHA, as well as employees and the public, it's anticipated that the quality and accuracy of the data will improve, to avoid violations. OSHA intends to use the collected information to more accurately identify patterns and trends to more effectively allocate its enforcement and compliance assistance resources, as well as develop effective workplace safety standards. Employers, employees and employee representatives will be able to use the collected data to improve workplace safety and health and increase access to the data.
The full list of affected industries is outlined by OSHA below and is organized by NAICS code.*