Another year has started, and employers are preparing end of the year paperwork and must get ready to file their annual… OSHA 300A form! That is right, just like filing their annual tax returns, OSHA recordkeeping requirements state employers must submit their annual injury data directly to OSHA.
If you are an employer and not quite sure if you must comply, you are reading the right blog article. We are here to provide the Who, What, Why, When, and How!
Who must comply?
The reporting requirements are based on the number of employees an establishment had at peak employment during the last calendar year. Each individual employed at any given time during the year counts as one employee, including full-time, part-time, seasonal and temporary workers.
Establishments with 20 or more employees from selected industries and all establishments covered by the recordkeeping rule with 250 or more employees must comply.
The most common type of industries (there are over 600 NAICS codes) that must comply are agriculture, utilities, construction, manufacturing, wholesale trade, general industry/other.
What data to submit?
OSHA is requiring employers to submit their injury and illness records from the previous year and this information can be found on the completed OSHA 300A form.
- Company name
- Establishment name
- Establishment full address
- Size of establishment
- Establishment type
- Employer EIN
- NAICS code & industry description*
- OSHA form 300A year
- Average annual employees
- Total Hours Worked
*OSHA is using the 2012 NAICS codes
- Total # of cases with days away from work
- Total # of cases with job transfer or restriction
- Total # of other recordable cases
- Total # of days away from work
- Total # of days job transfer or restriction
- Total # of death cases
- Total # of injuries
- Total # of skin disorders
- Total # of respiratory conditions
- Total # of poisonings
- Total Number of other illnesses
When to report?
The deadline for employers to electronically submit their 2020 OSHA 300A form is March 2, 2021, however employers can start submitting the required information starting January 2, 2021.
How to report?
In August of 2017, OSHA launched their Injury Tracking Application (ITA), a secure web site for electronic submission of the OSHA recordkeeping information. There are a few ways you can submit:
1. Manual Entry
For those organizations without access to OSHA recordkeeping software, you will be required to complete a manual submission to OSHA. You will first need to add your establishments to the application by creating profiles for them. Once you have set up your establishments, you can then enter and submit OSHA 300A data for each one via a web form.
2. Upload Data
For a quicker and simpler submission process, the ITA offers the option to upload a CSV file containing OSHA Form 300A data for all your establishments at one time.
3. OSHAlogs.com will submit for you
For companies using OSHAlogs.com, we will submit for you! No downloads required and no logging into the government websites. Simply verify your data and push submit! You will receive a confirmation and a record of the data that was submitted right within OSHAlogs.com.
Why is OSHA looking for this information?
Employers need to be prepared for OSHA inspections. OSHA will be using the submitted injury and illness information for Site Specific Targeting Inspection (SST). They will focus on workplaces with 20 or more employees and target by three categories.
- This first is HIGH-RATE ESTABLISHMENTS. Those are establishments with elevated days away, restricted or transferred rates (DART). OSHA will use different DART rates for manufacturing and non-manufacturing to achieve a 50/50 balance for inspections.
- The second category is LOW-RATE ESTABLISHMENTS. OSHA will identify for inspection representative establishments with low DART rates to address potential concerns regarding under-reporting of injuries and illnesses in the 2016 300As.
- Finally, those establishments that did not electronically submit their 300A reports, dubbed by OSHA to be “non-responders,” will receive additional attention regarding recordkeeping, likely including citations for failing to electronically submit.
For a complete 2021 Compliance Guidebook, information/sign-up sheet on how to subscribe to OSHAlogs.com, or to schedule a meeting to discuss your current OSHA recordkeeping contact us or fill out the form below.