OSHA Proposes to Revise Injury and Illness Log Submission Requirements

The Occupational Safety and Health Administration (OSHA) is proposing to amend its occupational injury and illness recordkeeping regulation to require certain employers to electronically submit injury and illness information to OSHA that employers are already required to keep under the recordkeeping regulation.

Specifically, OSHA proposes to amend its regulation to require establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year. Establishments with 20 or more employees in certain industries would continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year.

In addition, the proposed rule would remove the current requirement for establishments with 250 or more employees, not in a designated industry, to electronically submit information from their Form 300A to OSHA on an annual basis.

OSHA intends to post the data from the proposed annual electronic submission requirement on a public website after identifying and removing information that reasonably identifies individuals directly.

OSHA has developed a list (Appendix A) of Industries that will be required to continue to electronically submit  Form 300A  annually if they have 20 or more employees . The second list (Appendix B) includes   the industries that OSHA proposes to require submission of Forms 300, 301, and 300A annually if they have 100 or more employees.

Neither home health or hospice agencies are on the lists and therefore are not included in the proposed OSHA form submission requirements. Additionally, since OSHA is  proposing to eliminate the requirement for employers with 250 or more employees to submit the Form 300A, large  home health and hospice organizations will no longer be required to comply with this requirement if OSHA finalizes its proposed submission provisions.