Changes to Recordkeeping Submission Requirements Announced

On July 17, 2023, OSHA announced it is expanding the submission requirements related to recordkeeping requirements for employers in certain designated high-hazard industries.  The updated rule takes effect on January 1, 2024.  Employers have gotten used to submitting their 300A summaries electronically, but now those with 100 or more employees must also submit their 300 Log and 301 Injury and Illness Reports along with the 300A Summary.  

OSHA intends to publish some of the data that is collected from these submissions allowing employers, employees, potential employees, employee representatives, current and potential customers, researchers, and the general public to review it. This practice was first discussed in 2017 when online reporting first began but was placed on hold until now.  

To facilitate online data submission in accordance with the requirements, it is recommended to maintain 300 Logs, 300A Summaries, and 301 Injury and Illness Report in electronic form.  The online submission window is different than the required posting of the 300A summary, so it is suggested to set a reminder in your calendar as a best practice to ensure that the information is entered in a timely fashion. The online reporting portal opens on January 1^st and will close March 2^nd.

If you are not certain if your industry is subject to this reporting requirement, review the list of Partially Exempt Industries linked here:

Recordkeeping – Non-Mandatory Appendix A to Subpart B — Partially Exempt Industries | Occupational Safety and Health Administration (osha.gov) 

Tags: OSHA, Recordkeeping