Electronic Submission of OSHA Form 300 and 301 Data
For a while, OSHA only required some employers to electronically submit OSHA 300A information. But now, starting January 2024, OSHA is now requiring certain employers to also electronically submit, in addition to the OSHA 300A, OSHA 300, and 301 information.
New OSHA Form Electronic Reporting Requirements
Establishments with 100 or more employees in designated high-hazard industries (listed in Appendix B to Subpart E of 29 CFR Part 1904) must 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). The information to be submitted will include:
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.
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.
Retains the requirement for all establishments with 250+ employees in industries that must routinely keep records to submit the OSHA Form 300A Annual Summary.
Each establishment must provide their legal company name when submitting their data.
Which Companies Have to Electronically Submit the OSHA Form 300 and 301 Data?
Companies that had a peak employment of 100 or more employees during the previous calendar year meet the size criteria.
The designated industries are listed in Appendix B to Subpart E of 29 CFR Part 1904.
The requirements apply to establishments covered by Federal OSHA, as well as establishments covered by states with their own occupational safety and health programs (i.e., State Plans).
How Do I Submit the OSHA 300 and 301 Data?
The data must be electronically submitted through OSHA’s Injury Tracking Application (ITA). There are 3 ways to submit the data:
web form on the ITA;
submission of a CSV file to the ITA;
use of an application programming interface (API) feed.
When Is the OSHA 300 and 301 Data Due?
The ITA will begin accepting 2023 injury and illness data on January 2, 2024. The due date to complete this submission is March 2, 2024. Just like the OSHA 300A data, the submission requirement is annual, and the deadline for timely submission of the previous year’s injury and illness data will be on March 2 of each year.
Other Facts about the New Rule OSHA Recordkeeping Rule
OSHA estimates approximately 50,000 establishments will be required to submit their case-specific injury and illness data.
OSHA estimates they will submit information on approximately 750,000 injury and illness cases annually. Focusing the requirements on establishments with 100 or more employees in higher hazard industries means that fewer than one percent of establishments in the country will submit additional data, but the injury and illness data submitted by those establishments will comprise nearly 30% of all reportable occupational injuries and illnesses.
OSHA estimates it will cost affected establishments with 100 or more employees an average of $136 per year to comply.
Contact Brandy today if you need assistance complying with the new recordkeeping rule!
This blog was written by Brandy Zadoorian, CSP, and Triangle Safety Consulting LLC's Owner and Principal Consultant.
She offers audits, expertise, resources, and guidance to help small to medium-sized manufacturing facilities improve their safety program, including compliance with OSHA Requirements.
She is a Certified Safety Professional (CSP) under the Board of Certified Safety Professionals.
