OSHA’s New Injury and Illness Online Reporting Requirement: A Sneak Peek

OSHAOSHA’s been busy making changes to the requirements for injury and illness record keeping and reporting.

In this post, we’re going to give you a screen-by-screen overview of a mock-up that OSHA created for their new injury and illness online reporting website.

If you’re in a hurry, scroll down until you see the first screen grabs. Otherwise, let’s take a short moment to review the recordkeeping and reporting changes first.

Recordkeeping Changes

On the recordkeeping front, there are changes that affect:

  • Who is required to keep records
  • Who is exempt from recordkeeping requirements

These changes are covered in this recent Convergence Training blog post and at this webpage from OSHA.

Reporting Changes

On the reporting front, there have been changes that affect:

  • What must be reported
  • How reporting will occur (specifically, there’s now an online component)

Again, you can read more about these changes in this recent Convergence Training blog post and at this webpage from OSHA.

Need an LMSEHS training courses, or other help with your safety training program? Contact Convergence Training to learn more.

OSHA’s New Online Injury and Illness Reporting Requirements

That’s all interesting and important stuff. But in particular, the new requirements for online submission of injury and illness data reporting is especially interesting. And that’s what we’re going to take a closer look at in this blog post.

You may remember that OSHA was proposing three changes to 29 CFR 1904.41 involving electronic recordkeeping. Those are:

First, OSHA will require establishments that are required to keep injury and illness records under Part 1904, and had 250 or more employees in the previous calendar year, to electronically submit information from these records to OSHA or OSHA’s designee, on a quarterly basis (proposed § 1904.41(a)(1)—Quarterly electronic submission of Part 1904 records by establishments with 250 or more employees).

Second, OSHA will require establishments that are required to keep injury and illness records under Part 1904, had 20 or more employees in the previous calendar year, and are in certain designated industries, to electronically submit the information from the OSHA annual summary form (Form 300A) to OSHA or OSHA’s designee, on an annual basis (proposed § 1904.41(a)(2) Annual electronic submission of OSHA annual summary form (Form 300A) by establishments with 20 or more employees in designated industries). The second submission requirement will replace OSHA’s annual illness and injury survey, authorized by the current version of 29 CFR 1904.41.

Third, OSHA will require all employers who receive notification from OSHA to electronically submit specified information from their Part 1904 injury and illness records to OSHA or OSHA’s designee (proposed § 1904.41(a)(3)— Electronic submission of Part 1904 records upon notification).

(source for the above)

That leads to any number of interesting questions. But certainly one of them is: “What will this online reporting interface look like?”

OSHA’s Online Reporting Mock-Up: A Screen-By-Screen Overview

Conveniently, OSHA’s provided a sneak-peek of their upcoming online reporting interface to us in the form of a mock-up. For more about OSHA’s mock-up, which we’ll summarize below, click here.

So let’s take a look at what they mocked up, shall we? Remember, the images and explanations copied below are taken from an OSHA publication titled “Mockup of Proposed Web-Based Mechanism for OSHA’s Injury/Illness Data Collection” that was published 3/21/2012, so things may have changed a bit.

For each screen on their website mockup, we’ll provide the following:

  1. The name of the screen
  2. Some general comments from us about that screen–that hopefully will make it easier to see what the screen does and where it fits into the website as a whole
  3. A picture of the screen so you can see it for yourself
  4. Some comments from OSHA about the screen, taken from the PDF that includes the mockup

OSHA Injury/Illness Online Reporting Interface Schematic Diagram

This is a schematic that represents the website as a whole. Each box represents different screens of the website, and the arrows show the general navigation paths.

At this bird’s-eye view, you can see:

  • The Home page includes a way to register and to log in
  • There’s a User Dashboard screen that serves as the place from which you begin the various processes
  • From the User Dashboard, you can review and/or update your past submissions, print your submissions, set your submission options (batch submit by Excel or XML), enter your establishment information and then complete Form 300A (that’s the horizontal flow in the middle of the screen), enter your establishment information and then complete Forms 300 and 301 (on the top of the screen),
  • Submit and receive confirmations of your submissions
  • Log out

OSHA Recordkeeping Mock-Up

OSHA’s notes about the screen above:

Actually, OSHA’s document has no notes for this screen. But I guess it’s straight-forward enough.

 The Home Page

Here’s the home page. You can see it includes ways to:

  • Register for the online system
  • Login after registering
  • Contact OSHA with question, comments, etc.

2 Home Page

OSHA’s notes about the screen above:

“For the purposes of this mockup, it is presumed that each submission is establishment-specific. Possible accommodations for “multiple” submissions (e.g., from a corporate location)—beyond batch submission—are not included in this mockup.

The Registration Screen

Here’s the registration screen. Registering looks simple enough, and the information you have to provide is pretty standard.

3 Registration Screen

OSHA’s notes about the screen above:

“This page will register users and auto-generate a unique user ID and Password. This information will be sent to the email address provided on the Registration page when the user clicks the “submit” button. The user ID and password will be used for multiple submissions by the same user (e.g., quarterly submissions, or from year to year). When registering, the user will also be prompted to answer a hint question that will be used for a “Forgot your password?” mechanism.”

Sample Registration Confirmation Email

After you register successfully, you’d get a confirmation email. That’s handy.

The email would include:

  1. The URL (web address) you’d type in to access the system
  2. Your username
  3. Your password
  4. Contact information if you have questions

Remember that we learned in the previous screen that OSHA’s website would automatically create your username and password.

It’s probably a good idea to save this email in a folder within your email system if you can (or do something else that will make it easier for you to find in the future). It’s probably NOT a good idea to print this out and leave it laying around where anyone can find it and use it.

As with a lot of these emails, notice that you shouldn’t reply back. But you’re probably used to that already.

4 Sample Email Confirmation

OSHA’s notes about the screen above:

Again, they’ve included no notes here, but this one seems pretty straight-forward too. No harm, no foul.

Login Page

The login screen’s pretty basic, but I think that’s what you want in a login screen. Remember the system auto-generates your username and password when you register, and then sends that information to you via email.

There’s a handy “forgot my password” feature too. You’ll need to answer a security question–something like “what’s your mother’s maiden name?” or “what’s the name of your first pet?” to get a reminder about this.

5 Login Screen

OSHA’s notes about the screen above:

“”Registration link will take the user to #2 in this document.

“Forgot your password?” link will prompt user to respond to the hint question with the answer provided during user registration. If the correct answer is entered, an email will be sent (to the user email address entered during registration) with a login and url for resetting the user password.””

User Dashboard 1 of 2

This is the dashboard screen where you begin making your submissions.

The screen provides three links for making submissions depending on the number of employees you have and whether or not you’ve been notified by OSHA to submit reporting data.

The screen also mentions that there are two options for submitting–using the online forms or performing “batch submission” in Excel or XML format. The batch submission option would allow a corporation with multiple sites to submit data for all those sites in one “batch.”

As we’ve seen earlier, there’s a phone number you can call for help.

6 User Dashboard 1 of 2

OSHA’s notes about the screen above:

“Criteria link above will present the user with an informational pop-up describing the collection criteria:

• ANUALLY: All establishments with 20+ employees that operate in one of the industries specified in Appendix A to subpart E of Part 1904 and for whom RK is required under Part 1904.

• QUARTERLY: All establishments with 250+ employees and RK is required under Part 1904.

Batch submission instructions link above will present the user with an information pop-up that includes instruction for generating and submitting batch data (e.g., multiples from a corporate headquarters) in acceptable formats (MS Excel or XML).

Depending on the type of data submission, the user will click one of the 3 bullet links above and go to page 2 of the User Dashboard.”

User Dashboard 2 of 2-My Establishment Data Submissions

This second screen of the User Dashboard lets you:

  • View your previously submitted (and completed) submissions
  • View your incomplete submissions
  • Edit your complete and/or incomplete submissions
  • Create a new submission

You just click on the hyperlinked name in the Establishment Name column to edit a submission.

Check the notes below this image for the comments about this screen from OSHA, because they mention changing a few things, including adding a new column. They also mention that “corrections” (which I take to mean edits to a submission) will be time-limited (which I take to mean you can only edit a submission for a certain length of time before it you can no longer edit it).

OSHA’s notes about the screen above:

“The screen-shot above is not necessarily representative of the actual page. For example, an additional column will be added to these tables to indicate the type of submission (e.g., annual, quarterly, special collection). In addition, complete submissions will include previous “quarterly” submissions for those establishments required to submit quarterly (and possibly from previous years).

Users will be able to review and update completed submissions by selecting the Establishment Name link.

Corrections will be time-limited.

The “read-only” statement in the sample above will be deleted.”

Online Form, Page 1-Establishment Information

The Establishment Address Information screen is where you’d enter information about your establishment.

If you’re looking at the overall schematic, this is the first screen in the horizontal “flow” that runs through the middle of the schematic.

A few things to notice here are:

  • There’s a field for entering an SIC (although they offer an SIC look up feature). Here’s more about SIC numbers.
  • There’s a field for entering an NACIS. Here’s more about NACIS numbers.
  • There’s a field for entering your Establishment DUNS number (if available)

 

9 Establishment Address Information

OSHA’s notes about the screen above:

“This is the first of multiple data entry screens for all establishments submitting data. Users reach this page by selecting “Submit Data” on the previous Dashboard page. Exact data fields will be determined during system development.

Basic validation will be included to ensure that required fields are completed and that data is entered into the appropriate format (e.g., numeric entries only in phone fields.)

To minimize the level of effort per submission (e.g., quarterly submissions), data entered on the first form page (above) will be saved in the system and displayed for updating as needed.”

Online Form, Page 2-Log Summary & Employment Information (Form 300A)

This is the form where some establishments will enter the Form 300A information.

Check the notes from OSHA below this image. They mention that this form will only be seen by establishments with 20 or more employees:

  1. That operate in one of the industries specified in Appendix A to subpart E of Part 1904, and
  2. For whom RK is required under Part 1904, and thus
  3. Will submit summary data to OSHA annually

section-3

section-1

section-2

OSHA’s notes about the screen above:

“This form will only be seen by establishments with 20+ employees that (1) operate in one of the industries specified in Appendix A to subpart E of Part 1904 and (2) for whom RK is required under Part 1904; and thus will submit summary data to OSHA annually.

Basic validation will be included to ensure that required fields are completed and that data is entered into the appropriate format (e.g., numeric entries only in phone fields.)

In addition, ODI-specific validation can be incorporated to check for outlier data when the user clicks “submit.” See following page for an example.

Following submission of the 300A data, respondents will receive online confirmation and an email confirmation. See items 10 and 11.”

Example Data Validation Check

This pop-up window would appear if you input data incorrectly when you were filling out Form 300A. OSHA’s notes below mention that they’ll make similar pop-ups if you make a similar error with Forms 300 and 301.

Interestingly, if your data falls outside the expected parameters and you get one of these messages informing you of that, you’ll have the option to change the data or leave it as is. If you do that, apparently, you may get a phone call from OSHA soon to correct the error.

Anyway, I like computer systems that tell me when I’ve made a mistake or may have made a mistake, so I like this pop-up.

11 Data Validation Check

OSHA’s notes about the screen above:

“Upon submission, users will be notified if data entered fall outside of set parameters and will have the option to fix the data before continuing with data submission OR ignore the edit condition(s) presented and continue with data submission. (This is an assumption based on current OSHA Log data collection.)

This notification is presented as a pop-up on the data entry page when the user clicks the “submit” button.

There are a number of edit condition checks already in use on the current ODI Respondent’s website that can be incorporated into the new data collection site. See example above. These checks, however, are specific to the 300A data. New edit checks will need to be developed and tested for the 300 and 301 data.”

Online Confirmation

This is the message you get online to confirm your submission was accepted.

Notice that you cna return to your dashboard to review, update, and even print your submission.

12 Online Confirmation

OSHA’s notes about the screen above:

OSHA’s got no comments on this screen, but then again, there seems no need for it.

Email Confirmation

Not only do you get an online confirmation when you complete a submission, you also get an email. That’s handy.

Be sure to save these email confirmations–they could come in handy one day. You never know.

13 Email Confirmation

OSHA’s notes about the screen above:

Again-no comments.

And again-no real need.

Logout Confirmation

This is the confirmation you’ll see when you log out.

It’s a good idea to log out of the system and confirm that the logout succeeded so the next person who uses your computer can’t jump in and start creating problems.
14 Logout Confirmation

OSHA’s notes about the screen above:

““Log back in” link will return the user to the login screen.”

Online Form, Page 2-Complete Log (Form 300)

Here’s the online screen for completing Form 300.

Note that:

  • You’ll need the Adobe PDF Reader, which will probably already have, to complete this form online. But if you don’t have it, don’t worry–you can download it here from Adobe for free.
  • There’s a button for adding another form page
  • When you complete this form and then click the Go to Form 301 button, the online system will use some of the information on this form to auto-fill some of the fields in the 301. That’s handy.

This screen’s pretty straight-forward, but make sure to check the comments from OSHA below the image. They’ve been quite for the last few screens, but they’ve got quite a bit to say about this screen and the next one too.

15 Form 300

OSHA’s notes about the screen above:

“This form will only be seen by establishments with 250+ employees and RK required under Part 1904 that submit log 300 data to OSHA quarterly.

The example above shows the types of data that will be captured on this page. Some aspects of the look and feel may be adjusted during the development stage and will ensure that the data entry is straight forward and intuitive.

Users will have the option of adding another 300 log page. If they choose to “Add a Form Page,” they will get a blank form page like this one. The “Save Input” button will prompt users to (1) continue entering 300 data or (2) go to a Form 301 data-entry screen.

After entering Form 300 data, the respondent will click “Go to Form 301 Page” to input the Form 301 data. Data elements that are redundant between the two forms will auto-fill in the Form 301 (i.e., case number, employee name, date of injury/illness).

Following input of the 301 data, users will authorize and submit data (for both 300 and 301s). For quarterly submitters, it is anticipated that the system will give respondents the option to input data over multiple user sessions before the user authorizes the establishment’s quarterly submission.”

Online Form, Page 3-Incident Reports Form (Form 301)

This is the screen where you fill in Form 301.

You get here after filling in Form 300.

If you hit Submit on this page, you’ll submit both Form 300 and Form 301. The next screen you’d see is the confirmation of submission.

16 Form 301

OSHA’s notes about the screen above:

“This form will only be seen by establishments with 250+ employees and RK required under Part 1904 that submit 301 data to OSHA quarterly.

The example above shows the types of data that will be captured on this page. Some aspects of the look and feel may be adjusted during the development stage and will ensure that the data entry is straight forward and intuitive.

Users will have the option of adding more incident reports or, when finished, authorizing and submitting data. If they choose to “Add a Form Page” (i.e., another incident report page), they will get a fresh page like this one. By choosing “Authorize and Submit Data”, they will go to the next screen. The “Save Input” button will prompt users to (1) continue entering 301 data (i.e., get a blank 301 form) or (2) authorize and submit data. For quarterly submitters, it is anticipated that the system will give respondents the option to input data over multiple user sessions before the user authorizes the establishment’s quarterly submission.

As noted on prior page, data elements that are redundant between the Form 300 and the Form 301 will auto-fill in the Form 301 (i.e., case number, employee name, date of injury/illness).

Possible Data Validation: When the user selects “Authorize and Submit Data” the system will compare the number of incident reports entered to the number of rows entered on the Log 300 data page and notify the user about any discrepancies.”

Online Form, Page 3-Authorize and Submit Data (Forms 300 and 301)

This is the screen you’ll see after filling in forms 300 and 301 online.

17 Authorization and Submission

OSHA’s notes about the screen above:

“Following submission of the Form 300 and 301 incident data, respondents will receive online confirmation and an email confirmation. See items 10 and 11 above for examples.

Basic validation will be included to ensure that required fields are completed and that data is entered into the appropriate format (e.g., numeric entries only in phone fields.)”

Conclusion

Well, that’s it. Pretty interesting, huh?

What are your thoughts about the online reporting requirements? What are your concerns? We’d love to read more about them below–leave a comment if you’ve got a few minutes.

And speaking of questions and comments, OSHA has had a few public meetings and comment period extension on this one. Here are transcripts for meetings held on January 9 and January 10 in 2014. The comment period was then extended until October 14, 2014. Read more about that extension–which has now ended–here.

Need an LMSEHS training courses, or other help with your safety training program? Contact Convergence Training to learn more.

Jeffrey Dalto

Jeffrey Dalto

Jeffrey Dalto is an Instructional Designer and the Senior Learning & Development Specialist at Convergence Training. Jeff has worked in education/training for more than twenty years and in safety training for more than ten. You can follow Jeff at LinkedIn as well.

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