It’s 2024, and with the new year comes the March 2 deadline for OSHA’s Form 300A injury and illness reporting. This year also marks the start of the new Improve Tracking of Workplace Injuries and Illnesses rule.
The new rule, which was effective Jan. 1, 2024, amended federal OSHA’s injury and illness recordkeeping regulations to require employers with 100 or more employees in certain industries to electronically submit injury and illness data annually.
That’s down from the 250-employee cutoff of the old version of the rule.
Employers with 20 to 249 employees who are classified in specific industries with historically high rates of occupational injuries and illnesses won’t see any significant changes to how they report under this new rule.
What needs to be submitted and when
The bottom line is that the updated rule requires establishments with 100 or more employees in certain high-hazard industries to 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, on or before March 2.
These submissions are in addition to submission of the Form 300A Summary of Work-Related Injuries and Illnesses.
Revised rule allows OSHA to publish the data
Under the new rule, establishments are required to include their legal company name and details about the employee and the injury or illness when making their injury record submissions to OSHA.
The agency stated that some of the data it collects will be published “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.”
Making this information public “will ultimately reduce occupational injuries and illnesses,” OSHA said.
State OSHA plans must adopt similar rule
Employers in states that have their own federally approved OSHA plans will also have to adhere to this new rule.
“States with their own federally approved worker safety programs must set up reporting mandates that are identical to or similar to the federal plan,” according to law firm Ford Harrison. “The state plans will be able to use OSHA’s website rather than setting up their own submission portals.”
Maybe wait to submit records until closer to deadline this year
With the new rule comes OSHA’s new filing system, called the Injury Tracking Application, or ITA.
The OSHA website has a page loaded with information on the new reporting requirements and on how to use the new online filing system. There’s even a fact sheet on how to protect personal identifiable information.
However, along with the new system, there “could be early technical problems with the portal,” Ford Harrison said. “Covered employers may want to wait until closer to the March 2 deadline before submitting the required data” to give OSHA time to iron out any bugs.
