New OSHA Injury & Illness Reporting Requirements

Building upon amendments introduced in March of 2022, a new final rule from the US Department of Labor requires employers that operate in industries with high hazard rates to provide their injury and illness data directly to the Occupational Safety and Health Administration (OSHA) via electronic submission beginning on the first of January 2024. 

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The goal of the new submission procedure is to streamline the data collection and analysis process in order to enable regulators to identify and address emerging challenges more quickly as information becomes available.  

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These new requirements will apply to all companies or organizations that fall within the high-hazard industry category and have at least 100 employees. Those companies and organizations must now provide to OSHA data accounting for all of their Form 300 work-related injury logs as well as their Form 301 injury and illness reports on an annual basis. It is also now required that companies make these submissions using their legal company name in order to improve the consistency of the data and subsequent analysis.

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To be clear, these new requirements do not replace Form 300A summary of work-related injuries and illnesses, which must also be submitted. The new rule does not supersede any of the pre-existing Form 300A submission requirements including that companies and organizations with between 20 and 249 employees in high-hazard industries will continue with electronic submissions in line with current regulations, as will companies and organizations with 250 or more in industries currently mandated to keep OSHA updated about work-related injuries and illnesses.

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OSHA has made clear its intentions to publish the resulting data publicly on its website in order to provide access to the data not just to employees -including current, former, and potential - and the representatives of employees, but also data analysts and research teams as well as other stakeholders and interested parties in order to better inform their decision-making and the quality of their data-based work, which OSHA believes may further help reduce the incidence of workplace accidents and preventable health issues. 

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As explained by the Assistant Secretary for OSHA, the overarching aim of the new system is to better line up data-based efforts with the original purpose behind the Occupational Safety and Health Act in order to provide the general public with a more complete picture of workplace safety and the health risks involved.

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With better data in hand, OSHA will now be better equipped to minimize on-the-job illness and injuries via strategic intervention, outreach, and other enforcement mechanisms available to the agency when specific problems within industries or individual companies are identified. At the same time, on a macro level, the data can be utilized by health and safety professionals and organizations to continually distill insight and spot trends in support of improved workplace safety across a variety of industries. 

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The overall impact of the implementation should be very positive in terms of further emphasizing the necessity of timeliness and accuracy in data reporting with regard to workplace accidents and health problems. Employers will also be empowered to better proactively manage safety issues in order to prevent the occurrence of accidents and the spread of illness before they become a bigger problem, which should ultimately lead to much safer working environments across the board. 

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You can find this announcement here.