OSHA’s Newly Proposed Injury and Illness Record Submission Requirements

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In a series of previous posts, we wrote explanations of OSHA’s injury and illness recording requirements, including the use of Form 300, Form 300A, and Form 301.

This post, however, announces OSHA’s proposed plans to require employers to take the establishment-specific injury and illness data they’re already collecting and submit it electronically through a website (cue the requisite Obamacare-exchanges joke and rimshot audio file snippet here).

What Is OSHA Proposing?

They are proposing modifying the current injury and illness reporting requirements. The modifications would not change the kind of data employers need to collect—that stays the same. But the new modifications would require many employers to submit that information electronically to OSHA.

Is This in Effect Now?

OSHA’s just proposing the rule, so it’s not in effect now.

Is There a Public Comments Period?

Yes, the public has 90 days, ending February 6, 2014, to comment. There will also be a public meeting held on January 9, 2014.

Which Existing Regulation is Being Modified?

Part 1904. Specifically, they’re talking of adding three new electronic reporting requirements to 1904.41.

What Are the Three Proposed New Injury and Illness Reporting Requirements?

The first would require establishments that (1) are already required to keep records, and (2) have more than 250 employees to submit records to OSHA on a quarterly basis.

The second would require establishments that (1) are already required to keep records, (2) have more than 20 employees, and (3) are in certain industries with high injury and illness rates to submit their summary of work-related injuries once a year.

And the third would require all employers who receive notification from OSHA to submit specified information from their Part 1904 injury and illness records to OSHA or OSHA’s designee.

What Will OSHA Do With This Injury and Illness Reporting Data?

According to various OSHA resources, OSHA will:

  1. Post the data online
  2. Use the data to target compliance assistance
  3. Use the data to target enforcement resources
  4. Allow employers to compare their injury rates with others in the same industry

You Said OSHA Will Post the Injury and Illness Reporting Data Online?


Exactly What Data Would OSHA Put Online?

Here’s what OSHA has to say about that:

“OSHA intends to make the data it collects public, as encouraged by President Obama’s Open Government Initiative. The publication of specific data elements will in part be restricted by provisions under the Freedom of Information Act (FOIA) and the Privacy Act, as well as specific provisions within Part 1904.

OSHA may make the following data from the various forms available in a searchable on-line database:

  • All data fields from the OSHA Form 300A (Summary form)
  • All data fields from the OSHA Form 300 (Log) EXCEPT the employee’s name
  • The data fields on the right side of the OSHA Form 301 (Incident report), i.e., case number, date of injury or illness, time employee began work, time of event, what the employee was doing just before the incident occurred, what happened, what the injury or illness was, what object or substance directly harmed the employee, and the date of death if applicable.”

Has OSHA Posted More Information About These Newly Proposed Injury and Illness Recordkeeping and Submission Requirements?

Yes, check out these:

Jeffrey Dalto

Jeffrey Dalto

Jeffrey Dalto is an Instructional Designer and the Senior Learning & Development Specialist at Convergence Training. He's worked in training/learning & development for 25 years, in safety and safety training for more than 10, is an OSHA Authorized Outreach Trainer for General Industry OSHA 10 and 30, has completed a General Industry Safety and Health Specialist Certificate from the University of Washington/Pacific Northwest OSHA Education Center and an Instructional Design certification from the Association of Talent Development (ATD), and is a member of the committee creating the upcoming ANSI/ASSP Z490.2 national standard on online environmental, health, and safety training. Jeff frequently writes for magazines related to safety, safety training, and training and frequently speaks at conferences on the same issues, including the Washington Governor's Safety and Health Conference, the Oregon Governor's Occupational Safety and Health Conference, the Wisconsin Safety Conference, the MSHA Training Resources Applied to Mining (TRAM) Conference, and others.

One thought on “OSHA’s Newly Proposed Injury and Illness Record Submission Requirements

  1. We currently use online submission in Indiana. I have found it annoying only because it currently requires re-typing of information as opposed to using our existing resource. Interested to hear more on how this is moving along.

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