OSHA Rule Change: Injury and Illness Reporting

On July 17, OSHA announced an expansion to their existing injury and illness reporting rule that will take effect starting January 1, 2024. Here is a quick rundown of what’s changing, who is affected, and how you can be sure you stay compliant.

What is the new rule?

Currently, there are two categories of workplaces (often called “establishments”) that are required to submit annual injury and illness information to OSHA. Moving forward, there will now be three workplace categories that must submit annual OSHA reports:

• An establishment that has 20–249 employees AND is classified in one of the high-hazard industries designated in Appendix A of OSHA’s Injury and Illness Recordkeeping and Reporting Requirements
• An establishment that has 250 or more employees AND is required to maintain injury and illness records
• An establishment that has 100 or more employees AND is classified in one of the high-hazard industries designated in the new Appendix B of OSHA’s Injury and Illness Recordkeeping and Reporting Requirements
  • Note: this third category, along with Appendix B, was created under this forthcoming rule change.

Additionally, companies must now provide their company name in their annual submissions. OSHA noted they will publish some of the collected data on their website for “the general public to use...to make informed decisions.”

What actually gets submitted?

OSHA has three different recordkeeping logs that need to be maintained by all applicable organizations, but not all this information is required to be submitted.

• OSHA Form 301
  • Also known as an Injury and Illness Incident Report form, this contains specific information about any injury or illness deemed to OSHA recordable. This form must be submitted to OSHA by establishments with 100 or more employees in certain high-hazard industries, under the new rule.

• OSHA 300 Log
  • This log includes employee details and notes the extent and severity of each case (such as restricted work, days away from work, or a job transfer).
  • Like Form 301, the 300 Log must be submitted to OSHA by establishments with 100 or more employees in certain high-hazard industries, under the new rule.

• OSHA 300A
  • This form, often called the 300A Summary, is an annual summary of all work-related injuries or illnesses.
  • This form must be submitted to OSHA by all establishments outlined under the new rule (listed above).

Applicable establishments must submit the required information through OSHA’s Injury Tracking Application portal by March 2 for the previous calendar year (so, by March 2, 2024, for the forms covering 2023).

Keep in mind that while OSHA’s regulations do not require employers to report near misses, it is considered best practice for employers to keep a separate record of near misses to proactively identify situations that, if not addressed, could lead to an injury or illness.

They do encourage employers to record these situations for their own safety and health monitoring information.

How do I stay compliant?

While it may go without saying, training your entire workforce not only helps to minimize safety risks, it also means you are less likely to have an on-the-job injury or illness that needs to be reported.

Taking online safety training is convenient as each of your employees can receive training on a wide range of topics, from the uses of various PPE to understanding hazard communication and identifying common slip, trip, and fall dangers.

In addition, an EHS system that helps you log and keep track of incidents and other issues will be a huge time-saver when it comes time to report to OSHA. Take a look at HSI's EHS platform Incident Management solution to learn more.

And if you want even more tips, view this on-demand webinar that details what is needed and how you can better report: OSHA's 300 Log - How to Make this Easier with a Safety Management System

Contact HSI today to learn how we can help with everything from employee safety training to streamlining the OSHA reporting process.