OSHA has finalized a rulemaking to rescind the requirement for employers with 250 or more employees to electronically report injury and illness data from OSHA Forms 300 and 301. Electronic submission of data from OSHA Form 300A will still be required.
The Final Rule appeared in the Federal Register on January 25
, and will take effect on February 24, 2019 (i.e., 30 days after publication).
In addition to relaxing the injury and illness reporting requirements, the Final Rule adds a requirement
for employers to submit their Employer Identification Number (EIN)
electronically along with data from Form 300A. The requirement to include the EIN will take effect on March 2, 2020 and impact reporting of 2019 injury and illness data.
2018 data from Form 300A must be submitted to OSHA before March 2, 2019.
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Why Did OSHA Remove This Reporting Requirement?
OSHA Form 300A provides a generalized summary of employee injuries and illnesses that occur at work, while Forms 300 and 301 require more detailed information like employee name, job title, and a description of the injury
. OSHA has determined that electronic reporting of employee’s personal information poses a threat to worker privacy. Therefore, OSHA will require employers to submit the more generic information from Form 300A only.
Injury and Illness Recordkeeping & Reporting Still Required
Though OSHA will no longer require electronic reporting of data from Forms 300 and 301, employers are still required to keep these records. OSHA will continue to obtain these injury and illness records during workplace safety inspections and will enforce the recordkeeping requirements for employers.
Lastly, this rulemaking does not impact OSHA’s requirements for immediate reporting
within 8 hours of the death of an employee as a result of a work-related incident. Nor does it change the requirement to report within 24 hours any worker in-patient hospitalization, amputation, or loss of an eye as a result of a work-related incident (see 29 CFR 1904.39).
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