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Changes to OSHA Injury and Illness Electronic Reporting Requirements

Are you prepared for complying with OSHA’s revised injury and illness reporting requirements?  OSHA issued a final rule in 2019 to amend its injury and illness record keeping regulation (29 CFR 1904).   The changes eliminate the requirement for covered establishments with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report).

Establishments are still required to electronically submit information from OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). In addition, the requirement to electronically submit Form 300A for all covered employers with 20 or more employees remains in place. The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years has also not changed.

The electronic reporting changes went into effect with the goal of protecting worker privacy. By preventing routine government collection of information that may be sensitive, including descriptions of workers’ injuries, body parts affected, and other personally identifiable information, OSHA is avoiding the risk that such information might be publicly disclosed under the Freedom of Information Act (FOIA).

Note that the final rule does not change Form 300A posting requirements. Form 300A summarizing the injuries and illnesses recorded for the previous year must be posted from February 1 through April 30 each year. Even if no recordable incidents or illnesses occurred during the previous year, the 300A form must be completed and posted reflecting zero recordable cases.

Employers with 10 or fewer employees and business establishments in certain industry classifications (based on their NAICS code) are partially exempt from recording and submitting OSHA injury and illness records. For questions about applicability of this regulation to your organization, or for help meeting 2020 recording and reporting requirements please email [email protected].

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