The Occupational Safety and Health Administration’s (OSHA) final rule that expands occupational injury and illness recordkeeping requirements (29 CFR 1904.41) went into effect this week on January 1, 2024.
The updated rule requires employers in designated industries with 100 or more employees to electronically submit information from their Log of Work-Related Injuries and Illnesses (Form 300) and from their Injury and Illnesses Incident Report (Form 301) each year on or before March 2. The information required to be submitted includes the date, physical location, and severity of the injury or illness; details about the worker who was injured; and details about how the injury or illness occurred.
The designated industries are listed in Appendix B to Subpart E of 29 CFR Part 1904 and include food manufacturing, beverage manufacturing, plastics product manufacturing, hospitals, and waste treatment/disposal facilities.
The final rule continues to require electronic submission of information from the Summary of Work-Related Injuries and Illnesses (Form 300A) for establishments listed in Appendix A to subpart E with 20-249 employees. It also still requires submission of Form 300A for establishments with 250 or more employees in industries that are required to keep OSHA injury and illness records.
The data must be electronically submitted through OSHA’s Injury Tracking Application (ITA). The ITA began accepting injury and illness data on January 2.
Don’t forgot that for those industries required to prepare Form 300A, it must be posted from February 1 through April 30 each year! Note that only industries within certain North American Industrial Classification (NAICS) codes are required to comply with OSHA record keeping requirements. A list of exempt NAICS codes has been published by the Department of Labor. This list includes NAICS code 5417 (Scientific Research and Development Services such as establishments engaged in conducting biotechnology).
Even if your company doesn’t fall under mandatory recording requirements, we encourage as best practice that companies record injuries and illnesses and complete and post form 300A. In addition, in some cases, companies in exempt industries may specifically be asked to record injuries and illnesses by OSHA, the Bureau of Labor Statistics, or a state agency. Also keep in mind that all employers, including those exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye.
For assistance complying with the new injury and illness recordkeeping rule, OSHA has published a fact sheet and an FAQ on general reporting requirements.
For additional information about OSHA injury and illness recording and reporting requirements, or for help with preparing and submitting the forms and information required for your organization, please contact us.
Happy New Year from all of us at Safety Partners!
This blog was written by Beth Graham, Director of Quality, Research, and Training
