I have received a number of e-mails, text, and phone calls concerning OSHA’s change in their Electronic Filing of Injury and Illness data.
Bottom Line… 300A Annual Summary Data is all that is required to be submitted for those establishments that have 250 or more employees.
TIP: “employees” are that personnel on site that if they were to get injured would, in fact, go on your log! Just because you have 250 bodies on site, but half are temps or contractors that would NOT go on your OSHA log if they got injured, this exemption would NOT apply to your site.
The sites of 250 or more NO LONGER have to submit details from their 300 Log or the 301’s (or equivalent) in their annual submittals – JUST THE 300A data.
OSHA did a nice job of explaining the why, who, and what needs to be done going forward… (emphasis and links to forms and sources by me)
OSHA’s regulation at 29 CFR part 1904 requires employers with MORE THAN 10 employees in most industries to keep records of occupational injuries and illnesses at their establishments.
Employers covered by these rules must record each recordable employee injury and illness on an OSHA Form 300, which is the “Log of Work-Related Injuries and Illnesses,” or equivalent.
Employers must also prepare a supplementary OSHA Form 301 “Injury and Illness Incident Report” or equivalent that provides additional details about each case recorded on the OSHA Form 300.
At the end of each year, employers are required to prepare a summary report of all injuries and illnesses on the OSHA Form 300A, which is the “Summary of Work-Related Injuries and Illnesses,” and post the form in a visible location in the workplace.
The recordkeeping regulation also requires ESTABLISHMENTS WITH 250 OR MORE EMPLOYEES that are currently required to keep OSHA injury and illness records to electronically submit information from the OSHA Forms 300, 300A, and 301 to OSHA annually.
Establishments with 20-249 employees in certain designated industries are required to electronically submit information only from the OSHA Form 300A—the summary form.
To protect worker privacy, this final rule ELIMINATES the requirement that ESTABLISHMENTS WITH 250 OR MORE EMPLOYEES that are currently required to keep OSHA injury and illness records submit information electronically from their OSHA Forms 300 and 301.
These establishments, as well as establishments with 20 or more employees, but fewer than 250 employees, in certain designated industries, MUST CONTINUE TO SUBMIT INFORMATION ELECTRONICALLY FROM THEIR PART 1904 ANNUAL SUMMARY (FORM 300A) TO OSHA OR OSHA’S DESIGNEE ON AN ANNUAL BASIS.
The final rule also requires all establishments that must submit information electronically from their part 1904 annual summary (Form 300A) to submit their Employer Identification Number (EIN).
Elimination of the requirement that establishments with 250 or more employees submit information electronically from their OSHA Forms 300 and 301—a requirement that has not yet been enforced—does NOT change any employer’s obligation to complete and retain injury and illness records under OSHA’s regulations for recording and reporting occupational injuries and illnesses.