Most employers with 10 or more employees at an individual “establishment” i.e., physical location, have long been required to maintain the OSHA Form 300, Log of Work-Related Injuries and Illnesses–more commonly known as the OSHA 300 log and the OSHA 300A summary form. In 2017 OSHA expanded its requirements so that covered establishments submit their OSHA 300A electronically to OSHA using the Injury Tracking Application (ITA) by March 2nd for the previous calendar year. These establishments include:
- Establishments with 250 or more employees who are required to keep injury/illness records
- Establishments with 20–249 employees in industries listed in 29 CFR 1904 Subpart E Appendix A
On July 17, 2023 OSHA released a revision to the electronic reporting requirements where covered employers with establishments having 100 or more employees in 106 designated high-hazard industries listed in 29 CFR 1904 Subpart E Appendix B must electronically submit information from their OSHA 300 Log and Form 301 Incident Report (or equivalent form used for incident/accident reporting) in addition to their OSHA 300A by March 2, 2024 for calendar year 2023. This new regulation takes effect on January 1, 2024. See the full text of the Final Rule in the July 21, 2023 Federal Register.
Note: Since some establishments have more than one NAICS code, the OSHA ITA Frequently Asked Questions states that employers should choose the NAICS code that represents the activity that generates the most revenue and/or has the most employees.
OSHA plans to post this employer/establishment-specific injury and illness data on a public website and believes that making this data public will allow various stakeholders, including the general public, to make more informed decisions about workplace safety and health at a given establishment and ultimately result in a reduction in occupational injuries and illnesses. To preserve the privacy of employees involved in workplace accidents, OSHA will NOT include personally identifiable information in their postings.
Additional information can be found on the OSHA FactSheet: Improve Tracking of Workplace Injuries and Illnesses.
If this revised reporting requirement applies to any of your facilities, be ready to submit the required information on OSHA’s ITA website sometime between January 2nd – March 2nd, 2024. If you have questions or comments, please contact McConkey’s Risk Solutions Consultant Steve McCarty at steve.mccarty@ekmcconkey.com or 717-505-3184.
