December 14th, 2023 by Dakota Software Staff
The most wonderful time of year is fast approaching—OSHA reporting season! Well, perhaps “wonderful” isn’t the word many environment, health, and safety (EHS) managers would use to describe it, but Occupational Safety and Health Administration (OSHA) recordkeeping and reporting doesn’t have to be viewed as a stressful, confusing mess. By promptly reporting accurate data to OSHA, you play a vital role in shaping the future of safety not only at your organization, but nationwide.
If your organization has more than 250 employees in a given location (or 20 to 249 employees for certain industries), you must electronically file a summary log of injuries and illnesses to OSHA every year. This compliance obligation frequently evolves, however, so it’s important to stay informed on the latest regulatory developments. Here we’ll take a look at what’s new for the upcoming year, plus review a few key items that will help keep your recordkeeping and reporting on track.
OSHA periodically issues new rules to improve the tracking of workplace injuries and illnesses, and a final rule amending the recordkeeping and reporting regulation at 29 CFR Part 1904 was published in the Federal Register this past July. The good news is that the amendment does not require organizations to track and report any more information—however, data that is already being recorded under the rule that did not previously need to be reported now has to be electronically submitted to OSHA by certain covered employers.
Specifically, organizations that employ 100 or more workers in designated industries will now be required to electronically report data from their OSHA Forms 300 and 301 annually rather than the usual submission of the Form 300A summary. OSHA notes that it will not collect the following data from Forms 300 and 301:
Employee names or addresses
Names of healthcare professionals
Names and addresses of facilities where treatment was provided if treatment was provided away from the worksite
To clarify which industries are subject to this new rule, OSHA has updated the North American Industry Classification System (NAICS) codes used in appendix A that designate the industries still required to submit their Form 300A data, and it has added an appendix B that specifies the industries that will now be required to report Form 300 and 301 data.
The amendment also requires that organizations include their company name when electronically submitting their injury and illness data to OSHA. The rule also states OSHA’s intention to post some of the reported data it collects from electronic submissions on a public website (after identifying and removing any information that could directly reveal an individual’s identity).
This new rule becomes effective on January 1, which means that it must be followed for the 2024 reporting season. You can read the full text of the rule here for more details to help determine how your organization’s industry is covered under the amended rule.
Of course, the same reporting rules still apply in 2024 for every other organization that files an OSHA 300A form annually. There are several crucial details that covered organizations must keep in mind every year they report injury and illness recordkeeping data.
Know the difference between recordable incidents and first aid. Your OSHA 300 form data should only include recordable injuries and illnesses, not incidents that merely required the application of first aid. Do not record first aid occurrences “just to be safe”—this sort of misclassification is a big mistake when it comes to compliance. Learn more on how to differentiate recordable injuries from first aid here.
Log the right data on the right form(s). Once you’ve determined that an incident is recordable, it’s time to keep records of it in all the right places. The first form to fill out is OSHA Form 301, which will contain the most detailed information about the injury and/or illness (e.g., employee hire date, how the injury occurred, and where treatment was administered). Then, the OSHA Form 300 is where you log all recordable injuries/illnesses that occur over the course of the year, which includes more basic information and a standardized categorization of incidents. Both of these forms must be completed within seven days of the employer being notified of the incident. Finally, OSHA Form 300A is the year-end report that summarizes the data and must be electronically submitted to OSHA by March 2, 2024 (but you can submit as early as January 1).
Choose your best option for electronic submission of data. OSHA has three options for reporting via its Injury Tracking Application (ITA): Manual entry into a web form, upload of a CSV file, or transmission of data via an application programming interface (API) for those with automated recordkeeping systems. Some of these may sound simpler and more convenient than the others—one of the many reasons that electronic collection of data, paired with automation, is becoming essential to efficient EHS management.
Important note: Remember that certain severe injuries must be reported to OSHA on a much faster timetable than in annual year-end reports. Work-related fatalities must be reported within 8 hours; inpatient hospitalizations, amputations, or the loss of an eye must be reported within 24 hours.
If you’re in doubt on the finer details of these compliance matters, OSHA offers a great deal of recordkeeping guidance. However, you can also boost your confidence in accurate data—and its timely reporting—with an EHS software solution that helps you track incidents and plan and maintain a compliance calendar.
Dakota’s ProActivity Suite provides all of these features as well as an expert-curated regulatory database. Add this to regulatory alerts delivered straight to your inbox, and you can be confident that you’ll never miss an EHS compliance update, reducing the risks facing your organization.
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