OSHA’s Electronic Injury Reporting Requirements
Every year, millions of employers are required to keep track of their workers’ injuries and illnesses by recording them in what is often called an “OSHA Log.” The OSHA Logs consist of three separate documents: the Form 300 Log of Work-Related Injuries and Illnesses, the Form 300-A Summary of Work-Related Injuries and Illnesses, and the Form 301 Injury and Illness Incident Report. It is required for all applicable employers (employers with 10 or more employees in certain industries) to retain the last five years of each of these documents. OSHA (Occupational Safety and Health Administration) will request to see them as needed during inspections and enforcement actions.
Under a Final Rule (Federal Registry Doc # 2016-10443) that became effective on January 1, 2017, OSHA revised its requirements for recording and submitting records of workplace injuries and illnesses to require that some of this recorded information be submitted to OSHA electronically for posting to the OSHA website via the Injury Tracking Application (ITA). After additional public commentary and feedback from employers, a second Final Rule (Federal Registry Doc # 2019-00101) was published by OSHA amending its original recordkeeping regulation. The current Final Rule was published on January 25, 2019, and made effective on February 25, 2019.
According to OSHA, “the rule will also provide [them] with data to assist the agency in improving allocation of compliance assistance – help OSHA provide to employers who want to improve their safety standards – and enforcement resources, expanding the Agency’s ability to identify, target and remove safety and health hazards, thereby preventing workplace injuries, illnesses and deaths. It will also enable OSHA to conduct more rigorous evaluations of the impact of government injury prevention activities.”
Below are several points that highlight the current OSHA Electronic Submission Requirements:
Applicability: Who is required to submit this information to OSHA?
- Establishments with 250 or more employees at any time during the year that are currently required to keep OSHA injury and illness records.
- Establishments with 20-249 employees at any time during the year that are classified (SIC or NAICS) in certain industries with historically high rates of occupational injuries and illnesses. Please see list here.
Note: As of August 1, 2019, Maryland is the only OSHA-approved State Plan that has not yet adopted the requirement to submit injury and illness reports electronically. Contact information for each of the State Plans can be found here.
Establishments that meet any of the following criteria DO NOT have to submit their information to OSHA’s website. Remember, these criteria apply at the establishment level, not to the firm as a whole:
- The establishment’s peak employment during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
- The establishment’s industry is on the Non-Mandatory Appendix A to Subpart B – Partially Exempt Industries list regardless of the size of the establishment
- The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on this list.
Covered establishments must electronically submit information from their OSHA Form 300A. Beginning in 2019 and every year thereafter, the information must be submitted by March 2. This includes most of the manufacturing sector (those with NAICS codes 31-33) with historically high rates of occupational injuries and illnesses.
In 2020, an establishment’s 2019 Form 300A data must be submitted to OSHA’s website by March 2, 2020.
OSHA defines an establishment as “a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities.”
Furthermore, OSHA requires covered employers to submit their Employer Identification Number (EIN) electronically along with their injury and illness data submission from Form 300A, which will facilitate use of the data and may help reduce duplicative employer reporting.
How do you submit your 300A on the OSHA’s Injury Tracking Application?
The following methods can be used to submit your 300A data to the Injury Tracking Application:
- Manually enter the data into a web form
- Upload a CSV file to process single or multiple establishments at the same time
- Users of automated systems can transmit data electronically via an API (application programming interface)
Note: OSHA recommends entering the data using the web forms rather than by creating and uploading a CSV file.
Instructions for navigation of OSHA’s Injury Tracking Application (ITA website):
- Visit this website: https://www.osha.gov/injuryreporting/index.html
- Click on the following image on the right side of the page:
Photo Credit: OSHA.gov
- Click “Create an Account” and follow the instructions (please keep this information readily available just in case submission responsibilities change within the company to avoid delays in reporting)
- Once you are “live” on the website, create an establishment
- Add 300A Summary data (manually)
- Submit establishment data
- If uploading a CSV file with multiple establishments, click “Upload Batch File”
- To view your establishment, click “View establishments” on the home screen and edit information if needed
OSHA provides great step by step information on their website. See OSHA’s Job Aids How – To Documentation
Photo Credit: OSHA.gov
Tips on what to have readily available before submission:
You will need the following information readily available to efficiently and successfully sign up for an account and submit your required information to OSHA:
- Establishment name
- NAICS Industry Code
- Completed OSHA Form 300A for the previous year
Don’t forget, 2019 OSHA Form 300A injury and illness data must be submitted by March 2, 2020.
If you need further assistance utilize OSHA.gov FAQs about the ITA or contact U.S. Compliance. U.S. Compliance is fully prepared to assist you and your organization with this process. U.S. Compliance provides safety, health and environmental services to hundreds of facilities in the manufacturing and general industry sector across the country and can help you submit your OSHA 300A information electrically.