OSHA’s Improved Tracking of Workplace Injuries and Illnesses

OSHA’s final rule, Improve Tracking of Workplace Injuries and Illnesses, sets December 15, 2017, as the NEW date for compliance (a two-week extension from the December 1, 2017, compliance date in the proposed rule). The rule requires affected employers to electronically submit injury and illness data through the Injury Tracking Application (ITA) Launch Page.

OSHA is currently reviewing the other provisions of its final rule to Improve Tracking of Workplace Injuries and Illnesses, and intends to publish a notice of proposed rulemaking to reconsider, revise, or remove portions of that rule in 2018.

Who Must Comply
The rule applies to two groups:
1- establishments with 250 or more employees must electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report).
2- establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.
• Note: the ‘high hazard list’ does include construction and manufacturing as whole industries, which encompasses a lot of businesses across the country.
• Note: the following OSHA-approved State Plans have not yet adopted the requirement to submit injury and illness reports electronically: CA, MD, MN, SC, UT, WA and WY. State Plans have six months to create equal or more stringent versions of
the federal rule.

Compliance Timeline
The requirement became effective on January 1, 2017. The new reporting requirements will be phased in:
1- In 2017, all covered establishments must submit information from their completed 2016 Form 300A by December 15, 2017.
2- In 2018, covered establishments:
• with 250 or more employees must submit information from all completed 2017 forms (300A, 300, and 301) by July 1, 2018, and
• covered establishments with 20-249 employees must submit information from their completed 2017 Form 300A by July 1, 2018.
3- Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.

Hot To Comply
To begin, launch OSHA’s secure websiteInjury Tracking Application (ITA). The site offers three options for data submission: (1) manually enter data into a web form; (2) upload a CSV file to process single or multiple establishments at the same time; or (3) users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface).

Once in the ITA, you’ll need to create an account – entering basic information such as name, company, email, phone number, and a user name. Then once your email is confirmed, you’ll have to create your establishment – entering information as the establishment name, address, and NAICS Code. Finally, submit your data through a simple four-step process.

The photo below shows the ITA website, and how you’ll be prompted to submit your establishment data:







Once you’ve created your establishment, you’ll need to submit your OSHA 300A log:






For questions and/or more information about this brief, please contact us at (847) 392-8585