OSHA’s Updated Electronic Submission Requirements For Injuries and Illness

In a significant move to improve workplace safety and enhance transparency, the Department of Labor (DOL) has recently announced an expansion on the Occupational Safety and Health Administration’s (OSHA) record-keeping rule. On July 17, 2023, the DOL unveiled an expanded electronic documents submission requirement for injury and illness data provided by employers in high-hazard industries. The rule signals a commitment to fostering safer work environments and better equipping regulatory agencies to identify and address potential risks.

Understanding the rule

The updated rule, effective January 1, 2024, represents a fundamental shift in how injury and illness data is collected and shared. Employers operating in high-hazard industries, including manufacturing, retail, health care, performing arts, amusement parks, transportation, and deliver services will be required to electronically submit additional injury and illness documents, offering regulatory agencies deeper insights into potential risks and trends. This comprehensive data collection has the potential to transform workplace safety measures and significantly reduce incidents.

Key Highlights of the Rule:

1. Scope and Applicability: The rule focuses on employers operating within high-hazard industries, acknowledging that certain sectors are inherently riskier due to the nature of their operations. Previously, establishments with 20 to 249 employees in high hazard industries or all establishments with 250 or more employees were required to submit their Form 300A to OSHA once per year. Now, employers falling under this category and having 100 or more employees will be subject to the expanded submission requirements. You can find all the applicable industries that fall under this category in the link, Appendix B to Subpart E. This list can be filtered by the industry NAICS number.
2. Data Collection Expansion: Under the updated rule, employers will not only submit the standard OSHA Form 300A, but also the more detailed Form 301 for each injury or illness electronically. Form 300A is an annual summary of work-related injuries and illnesses that must be signed by a corporate representative and posted from February 1 to April 30 of the following year. The Form 300 is a log of work-related injuries and illnesses with more detailed information on each occurrence at the establishment, for that calendar year. The Form 300 contains information relating to employee health and must be used in a manner that protects confidentiality. Form 301 is the Incident Report for each injury and illness that provides details on specific injuries listed on Form 300. This richer dataset provides a more accurate and holistic view of workplace incidents, which enables regulatory agencies to identify patterns and potential areas for improvement more effectively.
3. Digital Transition: The expanded data submission will take place through OSHA’s Injury Tracking Application (ITA), a digital platform designed to streamline data collection, reporting, and analysis. This transition to a digital format eliminates the inefficiencies associated with manual data entry and improves the accuracy of the submitted information. ITA will begin accepting 2023 data on January 1, 2024, and it is due by March 2, 2024.
4. Informed Decision-Making: Regulatory agencies, armed with a broader and more granular dataset, can make data-driven decisions. Identifying emerging trends and high-risk areas allows for targeted interventions and the allocation of resources where they are most needed.
5. Transparency and Accountability: By sharing a wider range of data, employers enhance transparency and accountability in their commitment to safety. Employees, regulatory agencies, and industry stakeholders can collaborate more effectively to promote a safer work environment.

preparing for compliance

To navigate this rule seamlessly, employers should consider the following steps:

1. Educate and Train: Ensure that relevant personnel understand the updated requirements and how to accurately report data through the ITA platform.
2. Review Protocols: Evaluate and update existing reporting protocols to align with the expanded submission requirements. This might involve revisiting data collection procedures and refining internal reporting practices.
3. Stay informed: Regularly monitor updates from the Department of Labor and OSHA for any changes or clarifications related to the updated rule.
4. Start Now: Begin gathering 2023 incident data and updating your records now to ensure a smooth transition to ITA reporting which is currently scheduled for March 2, 2024.

ALL4 has assisted many companies in high hazard industries with their electronic reporting.  ALL4 can provide experienced consultants to assist in preparing for compliance.  ALL4 can provide training to the relevant personnel, review current protocols with feedback, and can provide up to date information on any changes from the DOL and OSHA. If you have questions or concerns about the updated rule and you’d like to discuss them, feel free to contact your ALL4 Project Manager or info@all4inc.com.