The following is Part I of our 2 part blog series on electronic submission of OSHA recordkeeping and improving tracking of workplace injuries and illnesses.

OSHA is aware that under-recording of injuries and illnesses is a serious problem. In fact, nearly every employer in the U.S. under-records injuries and illnesses on their OSHA 300. Most are unaware and some are far worse than others. OSHA feels workplace injuries will be reduced if injury data is available for public review and if employers are given the ability to compare their own injury experience with other businesses in their industry rather than the industry as a whole. For this reason, OSHA issued a new standard which requires some employers to submit their annual injury and illness data to OSHA electronically, some of which will subsequently be posted to the OSHA Website for public scrutiny.

Electronic submission of injury and illness records to OSHA, 1904.41, became effective on January 1, 2017.

Under the new rule, establishments which are required to maintain OSHA injury and illness records and having 250 or more employees on any day during the calendar year, will be required to electronically submit data from their OSHA forms 300, 300A and 301 each year to OSHA or their designee.

Smaller establishments with 20, but no more than 249 employees on any day during the calendar year and who have been identified in the list in Appendix A to Subpart E will be required to submit information from their OSHA form 300A each year to OSHA or their designee.

Employers not in either of these two categories will be required to submit the requested data only if notified by OSHA to do so.

OSHA will provide a secure Website for submission of the required information.

A few things to be aware of:

  1. The electronic reporting requirements are establishment-specific and are based on the size of the establishment, not the firm. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed.
  2. You will not be required to report the employees’ names from the OSHA 300 or, from the form 301, the employee home address (field 2), name of physician or other health care professional (field 6) or facility name and address if treatment was given away from the worksite.

The new reporting requirements will be phased in as described in Table 1:

Table 1

Please stayed tuned for Part II of this blog series coming soon!