By Adam R. YoungJames L. Curtis, Daniel R. Birnbaum, and Craig B. Simonsen

Seyfarth Synopsis: As a new update this year, certain employes are required to submit OSHA Form 300, 301 and 300A online.  OSHA recently offered a webinar on using it’s Injury Tracking Application (ITA) to submit this data.

Effective January 1, 2024, OSHA now requires some employers to upload OSHA Form information to its Injury Tracking Application (ITA) by March 2 of the following calendar year (i.e., 2023 data).  Employers must use the secure ITA website for injury and illness data submissions. Users may manually enter data, upload a CSV file to add multiple establishments at the same time, or transmit data electronically via the API (application programming interface).

OSHA previously hosted a webinar regarding the mechanics involving in electronically submitting the OSHA forms.  Only certain employers are required to comply with the new electronic submission requirements.  Last year, OSHA published a Final Rule that stating that establishments with 100 or more employees in high-hazard industries, which were already required to submit information from the OSHA Form 300A Annual Summary, must now also submit information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report. Employers should consider the number of employees and industry classification at a specific site establishment, rather than at the entire Company.  Companies that are unsure of their obligations can use the ITA Coverage Application to determine if they are required to electronically submit their injury and illness information to OSHA.

Under the rules, establishments that meet any of the following criteria during the previous calendar year do not need to electronically submit their information to OSHA:

  • The establishment’s peak employment during the previous calendar year was 19 or fewer employees, regardless of the establishment’s industry.
  • The establishment’s industry is listed on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the number of employees working at the establishment.
  • The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on Appendix A to Subpart E of OSHA’s recordkeeping regulation.

Readers may also checkout OSHA’s Injury Tracking Application training video.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.