Each January, we receive numerous inquiries from clients regarding OSHA record-keeping and the required submissions for the previous year. OSHA record-keeping can be intricate, with varying requirements based on industry and employee count. As of January 1, 2024, OSHA expanded its recordkeeping and reporting requirements.
To facilitate proper OSHA record-keeping, please adhere to the following guidelines:
- Establishments* with 250 or more employees that are subject to OSHA's record-keeping regulation will continue to be required to submit information from their OSHA 300A form to OSHA annually into the ITA(Injury Tracking Application).
- Establishments with 100 or more employees in certain industries are required to electronically submit information from their OSHA Forms 300 and 301 to OSHA on an annual basis.
- Establishments with 20 to 249 employees in certain high-risk industries will continue to be required to submit information from their OSHA 300A form to OSHA annually.
OSHA has developed a lookup tool for organizations to determine if they are covered by the new rule.
Submission of data can begin on January 2, 2024, but the OSHA Form 300A be completed by March 2, 2024. Industries that are exempt from OSHA recordkeeping rules can be found here - www.osha.gov/itareportapp.
Keep in mind that all employers, regardless of exemption status are required to report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye. Those instructions can be found here - Report a Fatality or Severe Injury | Occupational Safety and Health Administration (osha.gov)
*What constitutes an Establishment?
Each of your facilities may be considered a separate establishment. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location (e.g., construction, transportation, communications, electric, gas, and sanitary services), the establishment is represented by main or branch offices, terminals, stations, etc., that either supervise such activities or serve as the base from which personnel carry out these activities.
For instance, a Home Healthcare Agency with multiple branches would have an equivalent number of establishments and branches. However, a Home Healthcare Agency with only one main office would be considered as having one establishment.
Social service agencies often have multiple establishments, but those with fewer than 20 employees are exempt from reporting online.
OSHA Forms & Workers' Compensation
Friedlander Group diligently tracks all injuries within organizations, regardless of whether they were reported to the carrier. By maintaining comprehensive records, we can assist our clients effectively in completing their OSHA 300A Forms.
Through meticulous injury tracking, we can identify the root causes of injuries and implement meaningful corrective actions to reduce the likelihood of employee injuries and workers' compensation claims. For more insights on root cause identification and meaningful corrective action, please refer to our video, "What to Do When an Employee is Injured at Work."
Clients can access their injury reports via their client portal to aid in completing the OSHA 300A Form and ensure no incidents are overlooked. Access your client portal here.
If you require assistance with your OSHA 300A form, please reach out to Raymond Sullivan, Friedlander Group's safety specialist, at (516) 306-0481 or via email at firstname.lastname@example.org