OSHA will now require certain employers in high-hazard industries to electronically submit workplace injury and illness information via its Injury Tracking Application (ITA). OSHA announced this final rules on July 17, 2023 to be effective starting January 1, 2024. The additional information required to be submitted can be found in records employers are already required to keep.
Log of Work-Related Injuries and Illness must be electronically submitted to their Injury and Illness Incident Report under this new rule.
Injury and Illness Submission Expansion Requirements
- Certain establishments must electronically submit detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA 300 Log and 301 Incident Report forms (29 CFR 1904.41) to OSHA. This includes the date, physical location, and severity of the injury or illness; details about the worker who was injured; and details about how the injury or illness occurred;
- Only establishments with 100 or more employees in designated industries are required to submit case-specific information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report; and
- The data must be electronically submitted through OSHA’s ITA. Establishments are also required to include their legal company name when making electronic submissions to OSHA from their injury and illness records to improve data quality.
What Employers Qualify Under the Expanded OSHA Rule?
The expansion to injury and illness tracking retains current requirements for electronic submission of Form 300A information from certain high-hazard industry employers with over 20 employees. Employers with over 250 employees who are required to routinely keep OSHA injury and illness records are also retained.
OSHA has stated that by providing public access to some of the data collected will reduce occupational injuries and illnesses. Published data will be available to employers, current and prospective employees, representatives, current and potential customers, researchers and the general public.
Establishments with 100 or more employees during the previous calendar year and are in designated industries required to submit case-specific information from the OSHA Form 300 Log and OSHA Form 301 Incident Report qualify.
Another way to determine if an employer is required to report data electronically is by using OSHA’s ITA Coverage Application. The requirements apply to establishments covered by Federal OSHA and state occupational safety and health plans.
How to Submit Data Electronically to OSHA’s ITA
- Use the webform on the ITA;
- Submit a comma-separated value file to the ITA;
- or Use an application programming interface feed.
Submissions are due March 2, 2024. Annual submission is required and future deadlines of the previous year’s injury and illness data will be March 2 of every year.
Benefits of Injury and Illness Reporting Expansion
In addition to providing public access to injury and illness information, electronic data reporting will help OSHA identify establishments and industries with specific hazards. OSHA can then work with those establishments and industries through enforcement and/or outreach programs to address and mitigate hazards to improve worker safety.
An increase in the collection of Forms 300 and 301 will also result in more accurate statistics regarding work-related injury and illnesses, including specifics of occupation and industry.
Next Steps for Employers
Employers should review all requirements for the final rule to understand if they are required to submit electronic data or other regulatory requirements. Affected employers should update and implement compliance policies and procedures.
Jake Mahin, GSP
Safety and Loss Control Consultant
The content of this News Brief is of general interest and is not intended to apply to specific circumstances. It should not be regarded as legal advice and not be relied upon as such. In relation to any particular problem which they may have, readers are advised to seek specific advice. © 2023 Zywave, Inc. All rights reserved.
