New OSHA Reporting Rules Take Effect January 1, 2024
Most employers are familiar with the concept of recordkeeping using OSHA forms 300, 300A, and 301 and for a while now, certain employers have been subject to an annual electronic submission requirement for the 300 A summary data. This is an important submission since this data is used by OSHA to target employers for planned inspections. Now under the latest revision to the standard, effective January 1, 2024, OSHA is requiring business establishments with 100 or more employees in designated high-risk industries to also electronically submit information from their OSHA Forms 300 and 301 to the agency annually. This article provides an overview of the key requirements of 29 CFR 1904: Recording and Reporting Occupational Injuries and Illnesses.
OSHA Recordkeeping Forms
OSHA requires most employers with 10 or more employees to keep track of serious work-related injuries and illnesses. OSHA provides three specific forms to assist employers in recording and maintaining the required information related to these injuries and illnesses:
OSHA Form 300: Log of Work-Related Injuries and Illnesses
OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
OSHA Form 301: Injury and Illness Incident Report
You must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer. An establishment is a single physical location where business is conducted or where services or industrial operations are performed.
Posting the 300A
At the beginning of each new year, workplaces must review the 300 forms from the previous year and complete the 300A to summarize the information. Completed 300A forms must be signed by a company executive and posted in conspicuous locations throughout the workplace, so that all employees may easily review the injury and illness data from the previous year. Posting is required from February 1st through March 30th.
Online Submission to OSHA
As noted above, certain establishments must electronically submit their injury data to OSHA. The Injury Tracking Application (ITA) (https://www.osha.gov/injuryreporting/ita) is the secure government website for electronically submitting your data to OSHA.
For covered establishments, online submission can begin as early as January 2 and the deadline to submit all required 2023 injury and illness information is March 2, 2024.
Who Must Submit Online?
There are many factors to consider when determining if your workplace must submit online. If the establishment had 250 or more employees or had 20 or more employees but fewer than 250 and are classified as a high-hazard industry they must submit OSHA form 300 A information online. This list of high hazard industries can be found here.
Establishments with 100 or more employees in high-hazard industries to also submit information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report. That list of high hazard industries can be found here.
A useful tool OSHA provides is the ITA Coverage Application (https://www.osha.gov/itareportapp) to help employers determine if they are required to electronically submit their injury and illness information to OSHA.
Establishments covered by an OSHA-approved State Plan should directly contact their State Plan.
How can CMI Help?
CMI assists hundreds of organizations annually to ensure their OSHA recordkeeping forms are maintained and submitted properly. If you have any questions or need help with recordkeeping, please reach out to us.
Contact us today to set up a review of your OSHA 300 forms to ensure accurate reporting!
Written by: Rebecca Caffrey