Understanding the New OSHA Recordkeeping Rules: A Comprehensive Guide to Compliance

In July 2023, the U.S. Department of Labor announced a final rule that expanded the injury and illness information certain employers must submit electronically to OSHA. The rule took effect on January 1, 2024. This guide explains who is covered, what must be submitted, and when.

What does the rule require?

The OSHA rule added a new requirement for larger establishments in designated high-hazard industries. Under 29 CFR 1904.41, electronic submission now works like this:

• Establishments with 100 or more employees in an industry listed in appendix B to subpart E of part 1904 must electronically submit information from their OSHA Form 300 log and Form 301 incident reports once a year (1904.41(a)(2)). This is the requirement the rule added.
• Establishments with 20 to 249 employees in an industry listed in appendix A to subpart E must electronically submit information from their OSHA Form 300A annual summary (1904.41(a)(1)(i)).
• Establishments with 250 or more employees that are required to keep OSHA injury and illness records must also electronically submit information from Form 300A (1904.41(a)(1)(ii)).

The employee counts are based on the number of employees at any time during the previous calendar year. The information is due by March 2 of the year after the calendar year covered by the forms (1904.41(c)). Each establishment must also provide its legal company name when it submits its data.

Submissions go through OSHA's Injury Tracking Application.

Why is OSHA Compliance important?

Transparency is a key factor in improving workplace safety. OSHA has said that public access to establishment-specific, case-specific injury and illness data will allow employers, employees, customers, and the general public to make more informed decisions about workplace safety and health at a given establishment, and that it believes this access will ultimately result in the reduction of occupational injuries and illnesses. This rule represents a significant step towards realizing the objectives of the Occupational Safety and Health Act, and underscores the importance of OSHA compliance in creating safer workplaces.

What does this mean for your business and workplace safety?

Compliance with OSHA rules is not just about avoiding penalties. It's about ensuring the safety and well-being of your employees.

Start by confirming whether each of your establishments is in an industry listed in appendix A or appendix B, and how many employees it had during the previous calendar year. Then make sure your OSHA 300 log, 301 incident reports, and 300A annual summary are complete and accurate well before the March 2 deadline. Remember, creating a safe workplace is a continuous process, and staying informed is a crucial part of that process.

For hands-on help with OSHA recordkeeping, visit TSG Safety.