OSHA Injury and Illness Reporting Requirements | Updated 2023

As of Monday, July 17^th, 2023, the Department of Labor’s Occupational Safety and Health Administration (OSHA) announced the most recent changes to rules on electronic injury and illness reporting.

The most recent change was made in an effort to improve the reporting requirements in “high-hazard industries,” such as farming and construction. 

OSHA Electronic Reporting for Injury and Illness

Employers in high-hazard industries are required to keep detailed reporting of all injuries and illnesses taking place in the workplace. OSHA’s most recent changes to reporting have only to do with how electronic records are being submitted, and won’t necessarily change how an organization keeps such records.

Organizations with 100 employees or more are required to keep a few different records:

• OSHA Form 300: Data log of work-related injuries and illnesses. Form 300 is required to be kept on site in a secure place in case of an audit.
• OSHA Form 301: Injury and illnesses incident report. Form 301 is used to report and provide details about any injury or illnesses related incident.

Updates to Injury and Illness Reporting

What is the most recent update for electronic submissions of injury and illness reports? There are two main requirements within the update that employers will want to be aware of.

• Establishments in certain high-risk industries must electronically submit information for Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report to OSHA once a year. This requirement is made in addition to the submission of Form 300A-Summary of Work-Related Injuries and Illnesses that employers must already make.
• Employers must also list their legal company name when performing electronic submissions of all forms containing injury and illness records.

All employers in high-hazard industries with 100 employees or more should expect to be subject to the recent changes. The final rule will go into effect on January 1^st, 2024.

How Employers will be Impacted

The update to electronic submission requirements will impact certain high-hazard employers more than others. One of the specific industries OSHA is targeting with the new rule is warehousing and distribution centers. Such industries have come under attention for their increased exposure to risk in the workplace. Alongside “programmed inspections” under the new National Emphasis Program, the reporting submissions update will give OSHA access to more injury and illness data for industries similar to warehousing and distribution.

The new rule on electronic submissions will also give OSHA enough data to predetermine whether or not certain organizations fall under the instance-by-instance citation policy. In preparation of such circumstances, many establishments are choosing to hedge their health and safety protocols by working alongside a certified safety consultant and training team.

Furthermore, the advanced data OSHA expects to collect with the improvements made to electronic submissions may allow them to target employees who have reported injuries or illnesses in the past for interviews.

High-risk industries being impacted:

• Cattle Ranching and Farming
• Logging
• Fishing
• Water, Sewage, and Other Systems
• Foundations, Structure, and Building Exterior Contractors
• Dairy Product Manufacturing
• Animal Slaughtering and Processing

A note should be made that the above-listed industries are only a few of the many high-hazard sectors that will be subject to the update. Other industries included on the update’s final appendix B list, includes hardware manufacturing, product wholesalers, steel production, and many more.

Considering the recordkeeping employers are already required to keep in high-hazard industries, the most recent updates to electronic submissions may seem only a minor inconvenience. However, the updates are expected to go a long way in terms of improving OSHA’s data collection process on injuries and illnesses taking place in high-risk work environments.

Safer and Healthier Work Environment

The proposed changes to record submissions should allow all stakeholders within high-hazard industries to make more informed decisions about work safety standards and requirements. With the new changes, all stakeholders will have access to detailed injury and illness reports, including employers, employees, potential employees, employee representatives, potential customers, researchers, and more.

The information that won’t be released to stakeholders includes personal data related to an establishment or its employees (employee name, address, etc.)

The most recent changes are a part of a continuous shift in OSHA’s recordkeeping and submission requirements. Over the last several years, OSHA has made multiple updates to the rules on electronic submissions, and will likely continue to do so.

Safeguarding Against OSHA Rule Changes

It’s become apparent that certain high-risk industries may require advanced data submission requirements to protect the health and safety of employees in the workplace. While the insights provided through such changes will likely benefit employees overall, it doesn’t change the concern many employers have in keeping up with OSHA reporting requirements.

Every business has its own unique set of needs as far as safety training and management is concerned. At the same time, it can sometimes be difficult to match safety training requirements with the operational practices and expectations of the business.

At Riskill, our team of certified safety professionals specialize in creating custom safety solutions for your establishment. Having worked with firms in every major industry – from manufacturing to the energy business – we have the nuanced expertise required to make the right changes in your place of work.

We employ professionally trained and OSHA-authorized instructors to ensure all safety requirements are met within high-hazard industries. Feel free to reach out any time for more information on safety training and management solutions for your business.