Expansion of OSHA’s Injury and Illness Submission Requirements

OSHA (Occupational Safety and Health Administration) has introduced a significant update affecting employers, particularly those in high-hazard industries. This blog post breaks down the key points to help businesses navigate the new regulations.

Current Requirements:

Organizations with 20-249 employees in specific industries must electronically submit OSHA Form 300A annually. Establishments with 250 or more employees, required to maintain OSHA injury and illness records, must also submit Form 300A annually.

New Rule Effective Jan. 1, 2024:

OSHA’s final rule mandates additional electronic submission for certain employers in designated high-hazard industries. Employers in these industries must submit information from Form 300 and Form 301 in addition to the already required Form 300A annually.

Expanded Submission Requirements:

Employers with 100 or more employees in high-hazard industries must submit Form 300 and Form 301 to OSHA once a year, in addition to Form 300A. Legal company names are now required for electronic submissions to improve data quality.

Retained Requirements:

Current electronic submission requirements for establishments with 20-249 employees and those with 250 or more employees in certain high-hazard industries remain unchanged.

Data Publication:

OSHA will collect and publish data from Forms 300, 300A, and 301 on its website. Public access to this information aims to empower employers, employees, customers, and researchers to make informed decisions about workplace safety.

No Change in Record Obligations:

The final rule does not alter the obligation for employers to complete, retain, and certify injury and illness records under OSHA’s regulations.

Impact on Employers:

The new rule is expected to enhance OSHA’s inspection and enforcement efforts. Employers may see an increase in programmed inspections based on Form 301 data, including names of injured employees and injury details.

Greater insight into establishments’ injury and illness history allows OSHA to predetermine inspection focus areas.

Employers should anticipate increased compliance obligations, inspections, and potential citations.

Employers affected by the new requirements should proactively update and implement their policies and procedures to align with the regulations by Jan. 1, 2024. Staying informed and compliant will be crucial in navigating the evolving landscape of workplace safety regulations.

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