Did you know that OSHA has new electronic reporting requirements that take effect on January 1, 2024?

Covered entities are required to submit 2023 injury data electronically via OSHA's Injury Tracking Application (ITA) no later than March 2, 2024.

OSHA Form 300 Log and 301 Incident Report requirements for "High Hazard" industries

‍‍Changes were made to the reporting requirements for “High Hazard” industries - those whose North American Industry Classification System (NAICS) Codes appear in Appendix B to Subpart E of 29 CFR Part 1904.  

The new reporting requirements apply to establishments in those "High Hazard" industries who had peak employment of 100 or more employees during the previous year.

*** The electronic reporting requirements are based on the size of the establishment, not the firm. The OSHA injury and illness records are maintained at the establishment level. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment's peak employment during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.***

‍In addition to submitting 300A Summary data, those establishments must also submit 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 information covering:

 ·   The date of the injury or illness, 

 ·   Physical location where the injury occurred, 

 ·   Severity of the injury or illness, 

 ·   Information about the worker involved, and

 ·   Details about how the injury or illness occurred.

Note: the detailed information should not include any Personally Identifiable Information (PII).

Unsure what data should be submitted? Detailed information can be found under the "How To" section on the Injury Tracking Application (ITA) main page.

Learn more on OSHA's Injury Tracking Application Frequently Asked Questions page.

Changes may have been made to the Appendices, with different industries included or excluded compared to prior years.

We encourage you to review the following to determine whether or not your establishment falls within these requirements.

Appendix B to Subpart E of Part 1904 - Designated Industries for 1904.41(a)(2) Annual Electronic Submission of Information From OSHA Form 300 Log of Work-Related Injuries and Illnesses and OSHA Form 301 Injury and Illness Incident Report by Establishments with 100 or more employees in Designated Industries.

Appendix A to Subpart B - Partially Exempt Industries - Employers are not required to keep OSHA injury and illness records for any establishment classified in the following North American Industry Classification System (NAICS), unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye (see § 1904.39). The list of partially exempt industries is based on the 2007 NAICS codes. If an industry listed on the “Non-Mandatory Appendix A to Sub part B – Partially Exempt Industries” no longer exists in the 2017 and 2022 NAICS coding system, this would not change your partially exempt status. {See FAQ 2-3 and 2-4}. For a list of industries that are covered by this recordkeeping rule, click here.

You MUST submit 300A data if your establishment meets one of the following criteria:

1) 250 or more employees and is not in an industry listed in the Exempt Industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904, or

2) 20-249 employees and is in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904.

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For personalized help with your recordkeeping requirements and additional safety support, contact a Pinnacol Safety Consultant

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Additional Resources:

OSHA's FactSheet

OSHA's Injury Tracking Application FAQs

ITA Coverage Application (Find out if you are required to submit)

Visit OSHA's Injury Tracking Application (ITA) page to learn more