OSHA Recordkeeping deadlines are quickly approaching. By February 1, employers in the U.S. covered by the rule are required to prepare, certify and post a signed hard copy of their Summary of Work-Related Injuries and Illnesses (Form 300A) in a location accessible to employees to view. Employers at some establishments will also need to submit electronic injury and illness data to OSHA by March 2.
Here’s a quick recap of the important things you’ll need to know to meet OSHA Recordkeeping deadlines.
Who is Covered by the Recordkeeping Rule?
OSHA’s Recordkeeping Rule covers all employers with 11 or more employees in the company at any time during the calendar year, unless their NAICS code is included on the Partially Exempt List of industries OSHA considers to be low hazard. All employers covered by the rule are required to keep occupational injury and illness records including the Log of Work-Related Injuries and Illnesses (Form 300), individual Injury and Illness Incident Reports (Form 301s) for each recordable injury or illness, and the Form 300A.
Employers covered by the Occupational Safety and Health Act with ten or fewer employees in the company or those who are in one of the low hazard industries listed on the partially exempt list are not required to maintain these forms but still must report any fatalities (within eight hours), hospitalizations of one or more employees (within 24 hours) and incidents involving amputation or loss of eye (within 24 hours). Employers have several options for reporting these incidents to OSHA, as described on OSHA’s “Report a Fatality or Severe Injury” page.
Do I Have to Post Form 300A, And How Long Must It Stay Up?
If your establishment is part of a company that is covered by the recordkeeping rule, you must complete and post a signed hard copy of form 300A summarizing your facility’s 2019 occupational injury and illness data by February 1 of each year.
It’s important to note here that many employers at small establishments with 10 or fewer employees mistakenly think that the “small employer” exemption applies to them, and they don’t need to maintain, sign, or post the 300A, but remember, Recordkeeping applicability depends on company size, not establishment size. This means, if you’re responsible for multiple establishments at a company covered by Recordkeeping, you need to ensure that each individual establishment maintains its own records and posts a signed copy of the 300A in an accessible location during the required timeframe.
For example, let’s say you’re a branch manager of a smaller establishment that had no more than 7 employees at any one time last year. Your branch is part of a company that has 200 or more employees at any time and is not “partially exempt” by NAICS code, so the company is covered by the Recordkeeping Standard. Should you be maintaining your own OSHA forms at your branch. And should you sign and post the 300A? If you answered “yes,” then well done. If you answered “no” or had no idea, please feel free to review the information in this post again or check out our on-demand webinar for a deeper dive into the Recordkeeping Standard.
The form must be posted in a location that is clearly visible to employees and new applicants and must remain up until April 30. As a general rule of thumb, you should post the 300A in a place where employees know important company announcements are shared.
Who Must Sign Form 300A?
OSHA requires a “company executive” to sign Form 300A prior to it being posted. This expresses OSHA’s intent that the signer is an individual with a high degree of responsibility and authority for the facility. Since the signature certifies that the information in the document is “true, accurate, and complete,” OSHA considers this a crucial step, and views unsigned forms as noncompliant.
The question is, who does OSHA consider to be a company executive for purposes of signing/certifying the 300A? The regulation itself provides context here. Specifically, 1904.32 (b)(4) says that a company executive can be “an owner of the company (only if the company is a sole proprietorship or partnership),” “an officer of the corporation,” “the highest-ranking company official working at the establishment,” or “the immediate supervisor of the highest-ranking company official working at the establishment.” The site’s EHS person could sign if she or he met one of those criteria.
Do I Have to Post Form 300A Even If There Were No Recordable Injuries or Illnesses?
Yes, OSHA is very clear about this. All covered employers must fill out and post the summary annually, even if no recordable work-related injuries or illnesses occurred during the reporting year.
Do I Need to Electronically Submit Data to OSHA?
Maybe. Not every employer covered by Recordkeeping also needs to electronically report, but some of them do. You’d need to understand OSHA’s 2023 electronic reporting final rule which went into effect in January 2024 to see if the requirements apply to you.
At a very high level, the OSHA final rule creates 4 different categories of electronic reporting obligations, depending on establishment size and industry sector, as shown in the chart below.
|
Establishment size (# of employees) |
Industry sector |
Electronic injury and illness reporting requirements |
|
<20 |
All industries |
No electronic reporting requirements |
|
20-249 |
Listed in Appendix A of 29 CFR 1904 |
Electronic 300A reporting |
|
100+ |
Listed in Appendix B of 29 CFR 1904 |
Electronic 300, 300A and 301 reporting |
|
250+ |
All industries covered by the Recordkeeping Standard |
Electronic 300A reporting |
Here’s more detail about how requirements break down for each of the four categories of establishments listed in the table above.
Establishments with < 20 employees
If you have fewer than 20 employees at your establishment at any one time, you don’t need to do electronic injury and illness reporting, whether under current requirements or revised requirements. Just document your employee headcount, making sure it includes all eligible employees.
Certain establishments with 20-249 employees
Establishments with 20–249 employees in certain designated industries (listed in appendix A to subpart E) will continue to be required to electronically submit information from their Form 300A annual summary to OSHA once a year (final § 1904.41(a)(1)(i)).
Establishments with 100+ employees listed in the new Appendix B
Establishments with 100+ employees in certain designated industries (listed in new appendix B to subpart E) will be newly required to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year (final § 1904.41(a)(2)). The industries listed in new appendix B were chosen based on three measures of industry hazardousness.
Establishments with 250+ employees subject to Recordkeeping Standard
Establishments with 250+ employees in industries that are required to routinely keep OSHA injury and illness records will continue to be required to electronically submit information from the Form 300A to OSHA once a year.
What Reporting Period Should I Cover in My Electronic Reports?
The reporting period you’ll need to cover is the same as the reporting period reflected in the physical forms 300, 300A and 301 you need to maintain, specifically, the calendar year.
For both the physical Form 300A (which you need to complete, sign and post by February 1st) and your electronic submission of 300A data, if applicable, the reporting period is the calendar year. So, for example, if you’re required to make electronic submissions by the March 2, 2025 deadline, the data submitted would cover the 2024 calendar year, from January 1 through December 31, 2024.
How do I Submit Electronic Injury and Illness Data?
If you need to submit electronic injury and illness data to OSHA, you’ll use the Injury Tracking Application (ITA).
If you’ve never set up an ITA account, don’t worry much about it—you’ll probably find the process similar to setting up an online banking account. You’ll set up a user identification and an associated password, and you’ll get a confirmation email that will take you back to the login screen. From there you can start inputting establishment data.
The process is even easier if you already have a login.gov account for other federal government sites, because you can use the same login details for the ITA.
You can set up multiple people in your organization to be administrators within the ITA, and you can either enter your information manually or submit an electronic file in .csv format. The advantage of submitting a batch file is that you can submit a single file containing information for multiple establishments with reporting requirements and upload the information to the ITA in one shot.
Is There Any Way I Can Get Help Meeting OSHA Recordkeeping Deadlines?
Indeed, there is! Modern safety management software can help by making it easy for you and your workers to report incidents, document follow-up, and generate accurate OSHA forms. Even better, can access forms for multiple establishments from anywhere, at any time, and electronically submit forms to OSHA via the ITA.
If your current recordkeeping methods cause anxiety about meeting OSHA’s revised electronic reporting requirements, now’s the time to start looking for better alternatives.
Looking for Additional Information?
Hopefully, this blog will help you feel more prepared meeting your OSHA Recordkeeping deadlines, but if you feel like you need more information, we have you covered.
A great place to start would be to attend our on-demand webinar that takes a closer look at all facets of Recordkeeping compliance, from determining which workplace incidents are recordable or reportable, to completing the three required OSHA forms, to electronically submitting your data to OSHA if you’re covered by that requirement.
If, like many EHS professionals, you need more help with the basics of knowing which injuries and illnesses meet OSHA’s definition of “recordable,” you can download and use this handy cheat sheet.
Finally, if you have questions about electronic injury and illness reporting using the ITA, our electronic reporting FAQs eBook probably has the answers.
Be sure to follow this space for future updates about Recordkeeping and other areas of EHS and ESG management!
Let VelocityEHS Help!
You’ll have an easier time meeting your annual OSHA Recordkeeping deadlines and maintaining compliance with the Recordkeeping Standard throughout the rest of the year, if you have the right tools.
Our Safety Solution, part of our VelocityEHS Accelerate ® Platform, has incident management capabilities that can help you meet your OSHA Recordkeeping deadlines and other requirements, with mobile incident reporting and the ability to quickly attach photographs and other documentation to the inspection record. We also help you easily complete Forms 300, 300A and 301. Best of all, we make it easy to generate electronic versions of all three OSHA forms for easy transmission to OSHA via the Injury Tracking Application (ITA). And if you have reporting obligations for multiple establishments you can cut down on reporting time by putting information for multiple establishments on a single .csv file.
Visit our solution landing page for more information or just contact us anytime. And remember, incident management capabilities are only one way our VelocityEHS Accelerate ® Platform can help you, because you get plenty of other safety management capabilities, plus world-class ergonomics, chemical management and operational risk solutions, all in one platform offering an integrated user experience. Schedule a demo so you can see our platform in action for yourself!