Regulatory Deadline: OSHA Injury & Illness Electronic Reporting

/

March 2, 2022, is the deadline for electronically reporting your OSHA Form 300A data for the 2021 calendar year. OSHA began collecting data on January 2, 2022, and affected employers must submit the form electronically by March 2, 2022.

Each area OSHA office has access to the Injury Tracking Application database and OSHA indicates Compliance Safety and Health Officers (CSHOs) should refer to this database during all inspections to identify employers who were required to submit records but failed to do so.

Who must submit OSHA Form 300A?

Employers who meet one or more of the following criteria must submit Form 300A electronically by March 2, 2022:

  • 250 or more employees and are currently required to keep OSHA injury and illness records; or

  • 20 to 249 employees classified in specific industries with historically high rates of occupational injuries and illnesses, including construction, manufacturing, utilities, multiple types of retail stores, remediation, waste treatment and disposal, and more.

To submit electronically, employers must create an account in OSHA’s Injury Tracking Application.

What injuries and illnesses are recordable?

Employers in non-exempt industries with 10 or more full-time-equivalent employees (including temporary workers and contractors) must record each fatality, injury, or illness that:

  1. Is work-related,

  2. Is a new case, and

  3. Results in death; days away from work, restricted work, or transferred from usual work (DART); medical treatment beyond first aid, loss of consciousness; or a “significant injury or illness” as diagnosed by a medical professional.

Is COVID-19 a recordable work-related illness?

Employers must record work-related COVID-19 illness on their Form 300 logs if the following requirements are met:

  1. The case is a confirmed case of COVID-19;

  2. The case is work-related (as defined by 29CFR1904.5); and

  3. The case involves one or more relevant recording criteria.

Hospitalizations: Employers must report a hospitalization related to COVID-19 if it occurs within 24-hours of the SARS-CoV-2 workplace exposure.

Is a COVID-19 vaccination adverse reaction that occurs while at work recordable?

OSHA’s FAQ page relays “OSHA will not enforce 29CFR1904’s recording requirements to require any employers to record worker side effects from COVID-19 vaccination at least through May 2022”. We recommend re-evaluating the agency’s position at that time to determine the best course of action moving forward.

If you need assistance with OSHA Form 300A reporting, please contact us or call (800) 508-8034 to speak with one of our professionals today.

Blog Author

Diana Ludwig, STSC
Project Manager, Security, Safety & Health
KERAMIDA Inc.

Contact Diana at dludwig@keramida.com.