Dakota Software's Blog for EHS and Sustainability Professionals
December 10th, 2019 by Dakota Software Staff
Understanding the Occupational Safety and Health Administration's electronic reporting requirements is critical for all businesses that must file such reports.
Whether your organization has recently grown or changed to a point where it needs to ensure compliance with these health and safety reporting requirements or it wants to ensure effective ongoing adherence to them, a review of reporting requirements can be especially helpful. Let's look at the key considerations of OSHA injury reporting and the steps your company can take to improve its efforts to follow them.
A wide range of businesses must report individual and summarized injury and illness information to OSHA.
OSHA requires all businesses with 10 or more employees to maintain records of workplace injuries, as well as fatalities and illnesses. In the case of serious injuries, which are defined as work-related hospitalization, amputation or loss of an eye, all companies must report the incident to OSHA within a 24-hour period. For workplace fatalities, all businesses must share the information with the federal health and safety watchdog in eight hours. Those responsible for reporting the incident have three options:
OSHA also has more robust reporting requirements that follow an annual cycle. Due to a rule change first put into motion in 2016, companies above certain employment thresholds at individual establishments must file the required information with OSHA electronically. These rules apply to businesses with individual locations housing 250 or more employees, as well as companies in certain industries — including but not limited to retail, transportation services, community services and the performing arts — with between 20 and 249 employees.
The 2016 rule initially proposed requirements for annual reporting that included basic information, such as the company's name, address and industry, total headcount and number of hours worked, as well as injury and illness counts and statistics, which come from the OSHA Form 300A annual summary. Companies with more than 250 workers were also expected to share the data recorded on their OSHA Form 300 logs and OSHA Form 301 incident reports.
However, a rule change made in early 2019 removed the requirement to submit the Form 300 and Form 301 data, while maintaining the expectation that companies share Form 300A on an annual basis. OSHA explained its rationale for the change was due to concerns about potential access to information that could personally identify injured or ill workers through Freedom of Information Act requests. The actions of hackers and other cybercriminals are also worth considering in this regard. Companies still have to maintain these records on site, and OSHA may request them as part of inspections or enforcement actions, but businesses do not need to submit them electronically.
These reports — OSHA Form 300A, specifically — are due each year to OSHA on March 2. The reporting window opens on January 2, giving businesses the opportunity to file all the necessary data well before the deadline.
All establishments with more than 250 workers have to share annual incident data.
Businesses that have more than 250 employees at a specific location, and those in certain industries with between 20 and 249 workers, must file the required illness and injury information electronically on a yearly basis. OSHA has a dedicated injury tracking application that requires businesses to create an account but does not necessitate the purchase of outside software or tools. Businesses can use the forms offered by the portal or export a .csv file containing the same information. Your business may choose to contract a third party to maintain injury and illness records, submit that information to OSHA electronically or take both actions.
It's important to note that these requirements are based on the establishment level, as workers compensation specialist firm SFM pointed out. Establishments differ from the parent organization as a whole, which may operate several establishments under its banner. Only individual establishments that meet the worker count threshold have to file electronically.
Worker count is based on the highest employment level during the previous calendar year. For OSHA's purposes, that includes all types of workers, meaning not only full-time staff but part-time, temporary and seasonal employees as well. The count should include any employee who worked in a given establishment at any given time during the 12-month period, whether they worked there for only one day or the entire calendar year.
OSHA electronic reporting requirements differ based on the nature of the report submitted, the number of employees an establishment has, the industry it operates in and other factors.
For reports of individual qualifying incidents:
For annual reporting of OSHA Form 300A:
When businesses report individual incidents and yearly summaries of injuries, illnesses and fatalities to OSHA, they help the federal health and safety watchdog develop a stronger, broader understanding of incident trends throughout the country's economy. This data can then inform policy decisions on OSHA's part, as well as help shape specific initiatives focused on reducing especially common or dangerous types of accidents, exposures and illnesses in specific industries. Reporting this information ultimately helps OSHA do a better job of protecting American workers and crafting effective rules.