By Megan Coville, MS, OTR/L, ARM, CSPHP, CProMgrSU
Starting on January 1st, 2024, an additional requirement will go into effect for establishments, in certain industries, with 100 or more employees. This final rule indicates these establishments will not only maintain the OSHA 300 Log and OSHA 300a summary, electronically submit 300a summary data, also submit the OSHA Form 300A Summary, but they will also need to electronically submit information from their OSHA Form 300 Incident log as well as information from OSHA 301 forms, or employee incident forms.
|Size of Establishment (physical location)
|2017-2023 Electronic Reporting Submission Requirements
|2024 Electronic Reporting Requirements
|SAME – Form 300A Summary
|20-249 employees – certain designated industries (by NAICS codes – Appendix A to subpart E of part 1904)
|SAME – Form 300A Summary
|100+ employees – certain designated industries ((by NAICS codes – Appendix B to subpart E of part 1904)
|Form 300 Log and 301 incident reports – employee identifiable information excluded
Company vs. Establishment
An establishment is considered the physical location of an employer, not the total company. Some employers have multiple locations with their own employee base at any one of those locations. The number of employees associated with any one location is the number of employees to consider when determining if the establishment falls into one of these submitting categories.
Each establishment should be assigned its own North America Industry Classification System (NAICS) code. This code describes the type of work performed at the establishment. A company with multiple locations can also have multiple NAICS codes depending on the operations at each establishment. The combination of the size of the establishment and the NAICS code will determine a company’s Electronic Reporting requirements. NAICS codes are determined by the employer. Websites such as this can assist in determining the best code to assign to an establishment.
Establishments with over 250 employees will continue electronically submitting only their OSHA 300A forms. Establishments with 20-249 employees with NAICS codes on the Appendix A to subpart E of Part 1904, will also continue reporting their 300A Summary Form(s).
Establishments with 100 or more employees with NAICS codes on the Appendix B to subpart E of Part 1904 will be required to submit data from their 300 Log Form and specific data from their 301 forms or incident forms, in addition to the OSHA 300A Form.
What information will be included:
- OSHA Form 300 Log of Work-Related Injuries and Illnesses: Case # (field A), Job Title (field C), Date of Injury/Illness (Field D), Specific location (Field E), Description of injury/illness (Field F)
- OSHA Form 301 – Injury and Illness Incident Report, (or employer equivalent): Date of Birth (Field 3), Date Hired (Field 4), Gender (Field 5), Emergency Room Treatment (field 8), Hospitalization Inpatient (field 9), Case Number (field 10), Date of Injury/Illness (Field 11), Beginning of Shift Time (Field 12), Time of Event (Field 13), Description of Employee Activities Just Before the Incident (Field 14), Description of What Happened (Field 15), Description of Injury/Illness (Field 16), Objects / Substance Directly Harming the Employee (Field 17); Date of Death (Field 18)
If you are an employer who uses your own incident reports, that is okay as long as your forms are collecting the information that OSHA is requesting.
With all the information collected from the OSHA Form 301, OSHA does state it will not release establishment-specific data from these forms. The intention is to gather information for trending analysis purposes.
What data does not need be to be reported?
Data to be excluded to protect employee privacy is:
- OSHA Form 300 Log of Work-Related Injuries and Illnesses: Employee Name (column B)
- OSHA Form 301 – Injury and Illness Incident Report, (or employer equivalent) Employee Name (Field 1), Employee Address (Field 2), Name of Physician or Other Health Care Professional (Field 6), and Facility Name and Address if Treatment was Given Away From the Worksite (Field 7)
Why is OSHA doing this?
OSHA states the benefits of collecting this additional information is to allow for better analysis of trends in specific hazards while also helping to identify establishments who may benefit from outreach and/or enforcement to better protect employees. The data will also be available publicly which will allow stakeholders or potential stakeholders to make informed decisions about workplace safety and health at any given establishment.
How the data is submitted
OSHA plans to continue to enable three methods of data submission: manual data entry, batch file, and API. In manual data entry, the user enters the data into a web form and then submits the web form. In batch file submission, the user uploads a CSV file (a delimited text file in which commas separate the values). In API (application programming interface), the user uses a software program that communicates directly with OSHA’s data collection program.
When data is due
2023 data is due to be electronically reported by March 2nd of 2024.
OneGroup will help
OneGroup will be providing OSHA Recordkeeping and Electronic Reporting educational webinars in January. Please also feel free to reach out to the OneGroup Risk Management department for specific questions on OSHA Recordkeeping and Reporting.
To learn more reach out to Megan Coville, Director of Risk Management at MCoville@OneGroup.com.
This content is for informational purposes only and not for the purpose of providing professional, financial, medical or legal advice. You should contact your licensed professional to obtain advice with respect to any particular issue or problem. Please refer to your policy contract for any specific information or questions on applicability of coverage.
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