OSHA Electronic Reporting Changes and Due Date

On Jan. 25, 2019, the Occupational Safety and Health Administration (OSHA) issued a final rule formalizing changes to its electronic reporting requirements. Previously, establishments with 250 or more employees were going to be required to electronically submit data from their OSHA Forms 300 and 301 every year, in addition to data from Form 300A.

These requirements were originally part of OSHA’s 2016 final rule on electronic reporting but have never been enforced. OSHA first announced its intent to remove them in May 2018 and, in the meantime, has accepted electronic data from Form 300A only. The new final rule confirms that OSHA will not require electronic data from Forms 300 and 301 in the future.

OSHA Electronic Reporting Due By March 2

Each year, employers that are subject to the Occupational Safety and Health Administration’s (OSHA) electronic reporting requirements must submit data from their OSHA Form 300A (“Summary of Work-Related Injuries and Illnesses”) from the previous calendar year, using OSHA’s Injury Tracking Application (ITA). For 2018 information, OSHA started accepting electronic submissions as of Jan. 2, 2019.

Employers have until March 2, 2019, to complete their 2018 electronic reports. These requirements apply to:

• Covered establishments in a high-risk industry with 20-249 employees; and
• Covered establishments with 250 or more employees.   
• This is the first year that electronic reports are due on March 2.
• 2017 data was due by July 1, 2018, because OSHA’s 2016 final rule phased-in its deadlines until 2019.  
• Electronic reports will continue to be due on March 2 for future years.
• OSHA is not accepting electronic data from Forms 300 and 301.

ACTION STEPS

Employers subject to OSHA electronic reporting should begin entering data from their 2018 OSHA Forms 300A into OSHA’s ITA and ensure that all of the information is correctly entered and submitted by March 2, 2019.

OSHA Electronic Reporting

On May 12, 2016, OSHA issued a final rule that requires certain establishments to electronically submit information about work-related injuries, illnesses and incidents through the agency’s ITA website every year. The electronic reporting requirements apply to:

• Establishments that have 250 or more employees and are not in a partially exempt industry; and  

• Establishments that have between 20 and 249 employees and belong to a high-risk industry.

The electronic reporting rule also applies to establishments that receive a specific request from OSHA to create, maintain and submit electronic records, even if they would otherwise be exempt from OSHA recordkeeping requirements.

Under the 2016 rule, all covered establishments must electronically submit information from their OSHA Forms 300A every year. The rule also required covered establishments with 250 or more employees to electronically submit information from their OSHA Forms 300 and 301. Due to concerns about employee privacy, however, OSHA delayed its enforcement of the electronic reporting requirements for these two forms. In July 2018, the agency proposed removing them from the final rule altogether and announced that it would not enforce the final rule’s deadlines for Forms 300 and 301 without further notice.  

New Final OSHA Electronic Reporting Rule

OSHA’s new final rule, issued on Jan. 25, 2019, makes it official – OSHA will not require electronic submission of information from Forms 300 and 301. The change affects establishments with 250 or more employees only, since these were the only employers that would have been required to provide information from those forms under the 2016 final rule. However, these establishments, along with all other establishments subject to the electronic reporting rule, must still electronically submit 2018 information from Form 300A using OSHA’s ITA website.

In addition, all establishments subject to OSHA’s routine recordkeeping requirements must still record and keep information on Forms 300 and 301. The routine recordkeeping requirements apply to employers that are not in a partially exempt industry and have more than 10 employees. 

Finally, OSHA’s new final rule also amended the 2016 electronic reporting rule to require covered employers to submit their Employer Identification Number (EIN) electronically along with their injury and illness data submission. According to OSHA, this new requirement will facilitate the agency’s use of the electronically submitted data, and may help reduce duplicative employer reporting.

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