OSHA’s Revised Requirements for Submitting Injury and Illness Information Start Jan. 1, 2024
By Seth Skydel
Did you know that the OSHA final rule on requirements for submitting workplace injury and illness information takes effect on January 1, 2024?
Announced by the U.S. Department of Labor, the rule requires certain employers in designated high-hazard industries to now submit injury and illness information to OSHA electronically.
Employers are already required to keep the information. The change is that they now must report it electronically, not on paper forms.
The final rule includes the following submission requirements:
Establishments with 100 or more employees in certain high-hazard industries must electronically submit information from their Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report to OSHA once a year. These submissions are in addition to submission of Form 300A-Summary of Work-Related Injuries and Illnesses.
To improve data quality, establishments are required to include their legal company name when making electronic submissions to OSHA from their injury and illness records.
The final rule also retains the current requirements for electronic submission of information from Form 300A from establishments with 20-249 employees in certain high-hazard industries and from establishments with 250 or more employees in industries that must routinely keep OSHA injury and illness records. The designated industries are listed in Appendix B to Subpart E of 29 C.F.R. Part 1904.
One way to determine if your establishment(s) is required to report these data is by using our ITA Coverage Application. The requirements apply to establishments covered by Federal OSHA, as well as establishments covered by states with their own occupational safety and health programs (i.e., State Plans).
The data must be electronically submitted through OSHA's Injury Tracking Application (ITA). There are 3 ways to submit the data: (1) webform on the ITA, (2) submission of a csv file to the ITA, or (3) use of an application programming interface (API) feed. The ITA will begin accepting 2023 injury and illness data on January 2, 2024. The due date to complete this submission is March 2, 2024. The submission requirement is annual, and the deadline for timely submission of the previous year's injury and illness data will be on March 2 of each year.
OSHA will publish some of the data collected on its website to allow employers, employees, potential employees, employee representatives, current and potential customers, researchers and the general public to use information about a company’s workplace safety and health record to make informed decisions. OSHA believes that providing public access to the data will ultimately reduce occupational injuries and illnesses.
Benefits to OSHA: Access to establishment-specific, case-specific injury and illness data will help the agency identify establishments with specific hazards. This will enable the agency to interact directly with these establishments, through enforcement and/or outreach activities, to address and abate the hazards and improve worker safety and health. These same data will also allow OSHA to better analyze injury trends related to specific industries, processes or hazards. The collection and publication of data from Forms 300 and 301 will not only increase the amount of information available for analysis but will also result in more accurate statistics regarding work-related injuries and illnesses, including more detailed statistics on injuries and illnesses for specific occupations and industries.
Benefits to interested parties: Public access to establishment-specific, case-specific injury and illness data will allow employers, employees, potential employees, employee representatives, customers, potential customers, and the general public to make more informed decisions about workplace safety and health at a given establishment. In addition, researchers will be better able to identify patterns of injuries, illnesses, and hazardous conditions in workplaces. OSHA believes this access will ultimately result in the reduction of occupational injuries and illnesses.
“Congress intended for the Occupational Safety and Health Act to include reporting procedures that would provide the agency and the public with an understanding of the safety and health problems workers face, and this rule is a big step in finally realizing that objective,” explained Assistant Secretary for Occupational Safety and Health Doug Parker.
Seth Skydel is a writer with 38 years of experience covering the trucking, utility, construction, and related markets.
