Workplace Injury and Illness Reporting

As the deadline for filing Form 300A approaches on March 2, employers operating in what OSHA defines as high-hazard industries are pulling together their Form 300 injury and illness records for 2019. Maybe you’ve done it already. The submission period started on January 2, 2020.

If you haven’t sent anything to OSHA yet and need to familiarize yourself with the process, all forms and instructions are available at the OSHA website. Form 300A is submitted to OSHA electronically through the ITA launch page.

What’s new? The final rule about the tracking of workplace injuries and illnesses, published in the federal register on January 25, 2019, reflected some changes to the 2016 rule. Most importantly, OSHA no longer requires covered employers to electronically submit Form 300 (Log of Work-Related Injuries and Illnesses) or Form 301 (Injury and Illness Incident Report). There was significant push back from private industry about this requirement, and as a result, starting January 1, 2020, submitting Form 300A — a summary of incidents captured on Form 300 —is all that is required. Covered employers must still keep and maintain injury and illness data (Form 300 and 301) for five years, and have it readily available if needed.

The final rule also clarified some confusion about basic reporting requirements. Form 300A must be submitted if:

• You operate an establishment that is not exempt and has employed 250 or more people at any time during the previous year.
• You operate an establishment that is designated by OSHA as high-hazard, and you have employed 20 to 249 people at any time during the previous year.

It’s also important to remember that OSHA’s electronic reporting requirements are based on the industry classification of the “establishment” and not the industry classification of the “firm.” An establishment is defined by OSHA as “a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments.” Therefore, employers/firms with multiple establishments must determine peak employment at each establishment and include full-time, part-time, seasonal, and temporary employees in their calculation.

As you review your records and prepare your summary document, make sure that incidents meet the OSHA definition of what’s recordable. There can be understandable confusion about what “medical treatment beyond first aid “ means. If you’re not sure, see the OSHA website for details and to learn about special circumstances.

And even if you have no incidents, you still have to file Form 300A if you meet the other criteria. Just type zeros in each column and send it in.

If you have any questions or concerns about work-related injuries, illnesses, or OSHA Form 300A, feel free to contact me.

About the Author: James Laboe

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