New Application for Submission of Electronic Injury and Illness Records—2016 OSHA 300A forms due on Dec. 1, 2017

July 26, 2017

Following a number of postponements, OSHA has announced the launch of a new application for the electronic submission of injury and illness records to the agency. Employers will be required to upload their 2016 OSHA 300A form by Dec. 1, 2017, which was extended from the earlier deadline of July 1. The Injury Tracking Application (ITA), the system allowing for electronic submission of forms to the agency, will be accessible here on Aug. 1.

OSHA recently clarified that electronic reporting requirements are based on the size of the establishment or physical location, not the firm. A firm may have more than one establishment. Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records will be required to submit all necessary records electronically using one of three data submission options provided by OSHA.

  1. Manually enter data into a web form.
  2. Upload a CSV file to process single or multiple establishments at the same time.
  3. Transmit data electronically via an application programming interface (for users of automated recordkeeping systems).

Additionally, establishments with 20 to 249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses will also be required to submit injury and illness records electronically. However, these covered establishments will only be required to electronically submit information from OSHA Form 300A. A full list of these industries can be found here.

The new reporting requirements became effective on Jan. 1, 2017, and will be phased in over the next two years. All covered establishments must submit information from their completed 2016 Form 300A by Dec. 1, 2017.

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 to 249 employees must submit information from their completed 2017 Form 300A by July 1, 2018. Beginning in 2019, and every year thereafter, covered establishments must submit the information by March 2.

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