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Using electronic OSHA workplace injury forms

Apr 26, 2022

At the end of March 2022, the Occupational Safety and Health Administration (OSHA) published a proposal to improve tracking workplace illnesses and injuries that involves submitting every instance to their recordkeeping platform. However, this is not the first time the organization has submitted such an amendment to its recordkeeping policy.

This article will explore what the proposal entails and why it may receive further pushback.

OSHA's proposal

The proposal set by OSHA highlights its desire to change a number of policies:

  • Businesses with over 100 employees will submit OSHA Forms 300, 301, and 300A highlighting all illnesses and injuries to their recordkeeping platform at the end of each year.
  • Establishments with 1 to 99 employees or less will continue to submit information to the OSHA Form 300A per its usual cadence at the end of the year.
  • Organizations with 250 or more employees will no longer need to submit a Form 300A in their annual summary.
  • Establishments will need to include their company name within the electronic submission.
  • A new classification system that determines a list of industries covered by electronic records.

Currently, businesses that have 250 or more employees are required to submit an Annual Form 300A summary electronically to OSHA's Injury Tracking Application.

Some organizations are not required to follow the new amendment policies:

  • Employers with 10 or fewer employees at any given time within the calendar year will not need to submit OSHA Forms 300, 300A, or 301.
  • Certain industries are also not required to submit OSHA Forms 300, 300A, or 301, which can be verified within a list from OSHA using your North American Industry Classification System (NAICS) number. The list includes any business "where business is conducted or where services or industrial operations are performed," yet, this still includes employees who may not work at a single location, but are monitored and reported on by a branch of offices, terminals stations and so on.

OSHA estimates that the total cost of the amendments and adherence to the new policies will amount to $3,941,741 annually.

What may hold these policies back from getting passed?

OSHA made the proposal in 2016 during the Obama administration. It was delayed and later rescinded during the Trump administration and has since been repurposed, now under the Biden administration. The new proposal may lead to pushback by employers, their competitors, community activists and union organizers because all of the data OSHA collects is made public.

The reports do not need employee names, however, it may put those going through legal steps in a difficult position.

We always recommend that employers make the workplace as safe as possible, and that they follow safety protocol at all times. While the new proposal may require more steps at the end of each calendar year, we suggest that each organization follow the policies laid to remain compliant.

For more insights into industrial industry best practices, check out our blog.

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