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Managing OSHA’s Electronic Submission of Workplace Injury Data

By Casey Zambor, MA, CSP, Sr. Manager – Health & Safety, U.S. Compliance

In the ever-evolving landscape of workplace safety, OSHA’s Electronic Submission of Injury and Illness Data, also known as the ITA (Injury Tracking Application), plays a crucial role. This article aims to guide businesses through the intricacies of electronically submitting OSHA logs, focusing on who must submit, what to submit, and how to navigate the OSHA ITA website.

Who is Required to Electronically Submit OSHA 300 Forms?

Submission requirements hinge on the number of employees and industry classification. For instance, establishments with 250 or more employees that must routinely keep records are required to submit OSHA 300A injury and illness records. Similarly, establishments with 20 to 249 employees that are classified as industries with historically high rates of occupational injuries and illnesses must submit Form 300A annually (listed in Appendix B to Subpart E of Part 1904). High-hazard industries with 100 or more employees must submit their OSHA Form 300, Form 300A, and Form 301 (listed in Appendix B to Subpart E of Part 1904).

All covered establishments located in all states (including State-Plan states) must submit injury and illness records. So, if your establishment fits this criteria, it is required to submit injury tracking information on the OSHA ITA website.

The list of exempt industries (regardless of the number of employees) can be found in the Non-Mandatory Appendix A to Subpart B. It’s essential to stay on top of these changes to ensure compliance.

An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. The electronic reporting requirements are based on the industry classification and size of the establishment, not the industry classification or size of the firm.

What Information Must be Submitted on OSHA 300 Forms?

For the majority of businesses, submitting Form 300A (Summary of Work-Related Injuries and Illnesses) has been the expectation for the past six years. However, the recent update introduces the requirement to submit Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) in addition to Form 300A for establishments with over 100 employees in high-hazard industries. For guidance on filling out these logs, refer to our Preparing Your OSHA Logs – An Overview article.

How to Submit the Required Data for OSHA 300 Forms

Submitting OSHA data is done electronically through the OSHA ITA website. To begin the submission process, first create an ITA account and then create a Login.gov account with the same email address.

You will need the following information readily available to efficiently and successfully sign up for an account and submit your required information to OSHA ITA:

  • Completed OSHA Form 300A for the previous year (301 and 300 for certain establishments)
  • Establishment name & address
  • Employer Identification Number (EIN)
  • NAICS Industry Code

The system will prompt you based on your inputs, ensuring you provide all of the necessary information. Once your establishment is set up, you can manually enter the required data or explore other options like batch uploading via CSV files or using an API for efficiency. Having essential information ready, such as OSHA logs, total hours worked, establishment details, and your NAICS code, ensures a smooth submission process. It’s highly recommended to familiarize yourself with the process before submission to avoid any potential issues once the submission deadline approaches.

Deadline for Electronically Submitting Your OSHA Form 300

The deadline for submitting OSHA Form 300, 301, and 300A data for the previous year is March 2 annually. This deadline allows ample time to gather and input all of the necessary information. Also, keep in mind that OSHA 300A data must be posted in the workplace from February 1 to April 30. Proactive submission not only ensures compliance but also helps foster a safer work environment.

How is the Data Being Used?

Your submitted OSHA data isn’t just a formality—it plays a vital role in shaping workplace safety measures. OSHA utilizes this information to analyze trends, identify high-risk industries, and tailor their support system. The data aids in creating targeted inspections, national and regional emphasis programs, and overall transparency. By understanding incident trends, OSHA aims to enhance safety regulations, making workplaces safer for everyone.

Conclusion

Staying compliant with OSHA’s electronic illness and injury records submission requirements involves knowing who needs to submit, what needs to be submitted, and how to submit correctly. Navigating the electronic submission process ensures that businesses meet regulatory requirements, contribute to industry insights, and foster a culture of safety. Remember, it’s not just about compliance—it’s about contributing to a safer work environment and being part of a transparent and responsible workforce. If you have any questions or need assistance navigating the OSHA ITA, don’t hesitate to reach out to your U.S. Compliance Representative.

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