Under the rule, establishments with 250 or more employees that are currently required to keep OSHA injury and illness records are also required to electronically submit their Forms 300A, 300, and 301. 

Smaller establishments (with 20-249 employees) that are classified in certain industries with historically high injury and illness rates are also required to submit the 300A form (Summary of Work-Related Injuries and Illnesses).

The deadline for submitting 300A data to OSHA for Calendar Year 2017 was July 1, 2018. OSHA continued to collect CY17 forms until December 31, but submissions received after July 1 were flagged as “late.” 

OSHA will begin collection of CY18 Form 300A data on January 2, 2019. The deadline for submitting these data is March 2, 2019. Note this is much earlier than the past two years.

In July, OSHA published a notice of proposed rulemaking to amend the recordkeeping regulation to remove the requirements for submission of the Forms 300 and 301. That comment period closed on September 2018. The deadline for submitting these two forms for CY17 was July 1. 

OSHA will not enforce the deadline for these two forms, without further notice, while the rulemaking is underway.

Form 300 is a log of work-related injuries and illnesses that includes the injured or ill employee’s name; date of injury or illness; the location of the incident; a description of body parts injured and the object/substance that caused the injury; whether or not the injury caused lost or restricted time or a job transfer; the number of days lost, restricted or involving a job transfer; and whether the incident resulted in an injury or one of six illness types.

Form 301 is a detailed report of the injury or illness, consisting of 18 questions. 

Recordkeeping requirements

Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. (Certain low-risk industries are exempted.) Minor injuries requiring first aid only do not need to be recorded.

Maintaining and posting records

Records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. 

Electronic submission of records

The Injury Tracking Application (ITA) is accessible from the OSHA’s ITA launch page, where you can provide the agency your OSHA Form 300A information. 

Severe injury reporting

Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.

When is an injury or illness considered work-related?

According to OSHA, an injury or illness is considered work related if an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace, unless an exception specifically applies. See 29 CFR Part 1904.5(b)(2) for the exceptions. The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment. See 29 CFR Part 1904.5(b)(1).