As we see the end of 2024, we kickoff 2025 where it’s important for employers to revisit their compliance with OSHA’s recordkeeping requirements. The Occupational Safety and Health Administration (OSHA) requires certain establishments to electronically submit recordable injury and illness data beginning January 2, 2025. The data must come from the OSHA 300 Log and 301 Incident Report forms. Per 29 CFR 1904.41, OSHA ruled electronic submittals as the method required for all recordable injury and illness data that companies may have submitted in the past via other methods. OSHA provides a secure website where you can manually enter your data to the ITA via the web form, upload a CSV file to the ITA, or transmit data electronically via an API (application programming interface).
Why Does OSHA Want You to Report?
Injury and illness records collected from various industries and establishments help OSHA use this data when identifying common trends. This enables OSHA to interact directly with these establishments, through enforcement and/or outreach activities, to address and abate the hazards and improve worker safety and health. These recordkeeping requirements support OSHA’s mission of ensuring safe working conditions and providing transparency to employees on their company’s injury and illness records.
Is Your Company Required to Submit?
Employers with more than 10 employees who are not listed as exempt industries are required to keep a record of injuries and illness using OSHA or equivalent forms. You are also required to keep records if OSHA or the BLS has asked you to do to so in writing. It is best practice to keep records even if OSHA does not require you to do so.
Establishments with 100 or more employees in designated high-hazard industries (listed in Appendix B to Subpart E of 29 CFR Part 1904) must electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA Form 300 Log and Form 301 Incident Report (29 CFR 1904.41).
Not sure this applies to your company? Access the link below for more information to verify if your establishment meets the criteria:
https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppB
What Are the Recordkeeping Requirements?
For many employers, the year-end involves a thorough review of workplace injuries and illnesses. OSHA requires establishments to record specific work-related injuries and illnesses on the OSHA 300 log, a form that tracks these incidents throughout the year. In general, you should record work-related injuries (and illness) that results in death, loss of consciousness, days away from the workplace, restricted or light duty including job transfers and any medical treatment beyond first aid.
While the data should already be captured, businesses should also ensure:
- All incidents are documented accurately on the OSHA 300 log
- The details from the OSHA 301 Incident Report are included where needed
- The OSHA 300A Summary of Work-Related Injuries and Illnesses is posted in a visible location within your workplace (typically from February 1 to April 30 each year)
Note, you may not use your workers’ compensation loss runs to complete the summary as not all OSHA recordable incidents are workers compensation claims, and vice versa. Further, days away from the workplace are tracked differently between workers’ compensation and OSHA.
It is important to note that you must fill out and post an OSHA Form 300A even if your firm had no recordable injuries or illness events the prior calendar year. In this instance, you simply include a “0” for each entry – under then number of cases, days, and injury and illness type sections.
How Do I Electronically Submit?
OSHA has provided a secure website, the Injury Tracking Application (ITA), that offers three options for data submission:
- Users will manually enter data into the digital form
- Users are able to upload a CSV file to process single or multiple establishments at the same time
- Users of automated recordkeeping systems will have the ability to transmit data electronically via an API (Application Programming Interface). The ITA is accessible from the ITA launch page, where you are able to provide OSHA your 300A form information. The date by which covered employers are required to submit to OSHA the information from their completed Form 300 and Form 301 is March 2nd of the year after the calendar year covered by the forms. For example, all injury and illness data collected during 2024 will be required to be submitted electronically by the March 2nd, 2025 deadline.
ITA Tracking System: https://www.osha.gov/injuryreporting/ita/
Need Help with OSHA Recordkeeping & Reporting This Year?
Sentinel offers industry experts to help organizations grasp key concepts surrounding OSHA compliance, including recordkeeping requirements. We offer an array of services including onsite assessments, written and safety programs, training, and more to suit your company’s specific risk engineering solutions. Contact Sentinel today to learn more about Safeguarding Your Success.
