OSHA Proposes Injury & Illness Reporting Update

Posted on 4/1/2022 by Roger Marks

OSHA proposed a rule on March 30 to revise the injury and illness reporting requirements for employers.

Under the proposed rule, only employers in designated industries would be required to submit injury and illness data to OSHA annually. OSHA would remove the injury/illness reporting requirement for establishments with 250 or more employees that are not in a designated industry.

Some employers in designated industries would be required to submit more detailed data to OSHA each year from Forms 300 and 301. 

Under the proposed rule:
  • Establishments with 100 or more employees in certain designated industries would be required to submit information from OSHA Forms 300, 301, and 300A.
  • Establishments with 20 or more employees in certain designated industries would be required to continue submitting Form 300A (Annually Summary) each year.
OSHA Form 300A is the annual summary of workplace injuries and illnesses. Forms 300 and 301 include more detail about the injuries and/or illnesses summarized on Form 300A. The forms are available on OSHA's website.

Covered employers would still be required to keep records of workplace injuries and illnesses using the appropriate OSHA forms. The proposal also adds a requirement for establishments to include a "Company Name" with their data submission. 

OSHA will accept comments on the proposed rule until May 31, 2022.

Which “Designated Industries” Will Be Covered?

Currently, annual reporting of injury and illness data is required from employers in industries listed in 29 CFR 1904, Subpart E, Appendix A. The proposed rule does not change the list of covered industries; It will simply update the list to match current NAICS codes.

For example, the 2017 NAICS split group 4521 (Department Stores) into two groups, 4522 for “Department Stores” and 4529 for “Other General Merchandise Stores, including Warehouse Clubs and Supercenters.” As proposed, the updated Appendix A will list both codes.

Current Rules for Injury and Illness Reporting

Under the current OSHA regulations in 29 CFR Part 1904.41, the following employers must submit an annual summary of workplace injuries and illnesses (OSHA Form 300A):
  • Establishments with 250 or more employees that are required to keep OSHA injury and illness records; and
  • Establishments with 20—249 employees in certain high-risk industries.  
Removing the requirement for establishments with 250 or more employees that are not in high-risk industries to submit Form 300A would impact about 2,665 workplaces of that size that submitted the data in calendar year 2020, OSHA estimates.   
From the proposed rule: 

“OSHA has determined that collecting Form 300A data from this relatively small number of large establishments in lower-hazard industries is not a priority for OSHA inspection targeting or compliance assistance activities.”

For covered employers, electronic reports of injury and illness data are due each year by March 2.

For details about the types of workplace injuries and illnesses that employers must record to comply with OSHA regulations, read 9 Exceptions to OSHA Injury and Illness Reporting 

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Tags: injury reporting, osha, OSHA Form 300

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