OSHA Issues New Safety Reporting Requirement for High-Hazard Employers

By Rob Eckwall on Feb 07, 2024
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As of January 1, 2024, the Occupational Safety and Health Administration (OSHA) Improve Tracking of Workplace Injuries and Illnesses Rule requires certain businesses to electronically submit Forms 300 and 301, which summarize work-related injuries and illnesses from the previous year. The new reporting requirement applies to companies with 100 or more employees in industry categories OSHA designates as “high-hazard.”

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Who Is Affected By the New Rule?

Some of the industries impacted by the new rule include: 

  • Construction 
  • Manufacturing 
  • Food manufacturing 
  • Utilities 
  • Transportation 
  • Healthcare 
  • Agriculture/forestry 
  • Grocery stores 
  • Warehousing and storage 
  • Steel and metals manufacturing 
  • Building material and supplies dealers 
  • Commercial and industrial machinery and equipment (except automotive and electronic) repair and maintenance 

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Overview of the Rule's Forms and Submission Deadlines

The final rule announced by the U.S. Department of Labor in July 2023 now requires employers in industries with high injury and illness rates – like those above – to annually submit Form 300, “Log of Work-Related Injuries and Illnesses,” and Form 301, “Injury and Illness Incident Report,” through OSHA’s electronic reporting system, called the Injury Tracking Application (ITA). The submission deadline for OSHA Forms 300 and 301 is March 2, 2024. 

OSHA defines the companies impacted by the amended recordkeeping requirement as those “that had a peak employment of 100 or more employees during the previous calendar year.” 

All employers covered by the revised OSHA Improve Tracking of Workplace Injuries and Illnesses Rule are already required to collect and retain details about each recordable injury and illness employees experienced during the prior year. These are reported using OSHA Form 300A, a one-page “Summary of Work-Related Injuries and Illnesses,” which affected businesses now must post through OSHA’s ITA between February 1 and April 30, 2024.  

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Transparency and Compliance Challenges

Previously, OSHA only gathered that information for internal purposes. The new rule, however, stipulates that OSHA will publish on its website the workplace safety data employers provide. The motive behind the change is increased transparency. 

In the past, OSHA only learned the extent of safety incidents if its personnel physically inspected a work site. The agency now will use companies’ electronically submitted data to analyze occupational injuries, illnesses and hazardous conditions. Further, anyone seeking to evaluate a company’s safety record will be able to access its safety information online, which could positively or negatively impact a company’s reputation, depending on the frequency of injuries at its workplaces. 

Similarly, companies themselves can evaluate the publicly shared workplace safety data to compare their results to competitors’, recognize dangerous patterns and proactively improve safety conditions before an OSHA inspector knocks on their door. 

Besides the new reporting requirements companies must understand and adhere to, they also must be careful to not include on the OSHA forms where they record work-related injuries and illnesses any non-mandatory information (known as personally identifiable information, or PII) that could directly identify employees. Failing to comply with any of these OSHA regulations could result in costly fines and time-consuming abatement. 

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How Axcet HR Solutions Can Assist

Tracking every new OSHA rule and complying with federal labor law requirements can be especially challenging for smaller businesses, which don’t have deep benches of experts to keep up with frequently shifting regulations. Axcet HR Solutions, a certified professional employer organization, can help.

We handle critical HR tasks like OSHA compliance so companies can stay focused on strategic activities that grow their businesses. Since 1988, we have helped smaller companies institute best HR practices that limit legal exposure and keep employees safe. Contact us today for a quick, free consultation to learn how you our HR expertise and keep your company in compliance with OSHA’s rules.  

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Written by Rob Eckwall

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