United States: Don't Forget — New OSHA Electronic Submission Requirements For Certain Larger And High Hazard Industry Employers Due March 2

As we reported at the time, in summer 2023 the Occupational Safety and Health Administration (OSHA) issued a new final rule amending its occupational injury and illness recordkeeping regulation and imposing new electronic reporting requirements on some employers.

Specifically, employers who had 100 or more employees at any point during the previous calendar year — as well as employers in certain high-hazard industries — must begin electronically submitting information from OSHA forms 300 and 301.

OSHA opened the portal for submission of the electronic data (OSHA's Injury Tracking Application (ITA)) on its website on January 2, and employers who are required to submit the additional data and information must complete the submission process by March 2, 2024.

Per OSHA's Fact Sheet on the newly expanded requirement:

All the establishments required to submit information from their OSHA Form 300 Log and OSHA Form 301 Incident Report to OSHA under this rule are already required to collect and retain this information, and are currently required to electronically submit to OSHA information from their OSHA Form 300A Annual Summary.

[Under the new expansion, these same employers] must [also] electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year's OSHA Form 300 Log and Form 301 Incident Report (29 CFR 1904.41). 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.

The list of designated industries who must submit electronically are identified in Appendix B to Subpart E of the Recordkeeping Rule (29 CFR 1904).

Information on the new requirement (and compliance with the requirement that has been in place related to electronic submission of the OSHA 300A) can be found on OSHA's Recordkeeping landing page. Covered employers who have not yet made their electronic submissions should plan to do so prior to March 2.

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