OSHA’s 2024 Updates to 300 and 301 Forms for Accurate Safety Reporting / Mandatory Electronic Submission

OSHA 1904.29(a) requires organizations in high-hazard industries with 100 or more employees to submit forms 300, 300-A, and 301, or equivalent forms, for recordable injuries and illnesses. The OSHA 300 form is called the Log of Work-Related Injuries and Illnesses, the 300-A is the Summary of Work-Related Injuries and Illnesses, and the OSHA 301 form is called the Injury and Illness Incident Report.

Each recordable injury or illness must be documented within seven days of receiving information about a recordable injury or illness having occurred. The purpose of recording injuries and illnesses is to enable businesses to track incidents and prevent their recurrence in the future. Organizations can conduct investigations to identify the root cause for recurring or severe injuries and illnesses and take corrective and preventive actions to mitigate hazardous workplace risks. It also helps to inform employees about incidents and safe work behavior to minimize the risks.

The form must be filed before March 2 every year and all OSHA 301 forms must be stored for at least 5 years.

Since January 2024, OSHA has initiated changes to the OSHA 300 forms to make the data easily trackable and provide more insights to further mitigate safety risks and reduce the impact of the hazards.

Updated Requirements

As per the new requirements, certain establishments are required to electronically submit detailed information to OSHA about every recordable injury and illness that occurred in the organization in the previous calendar year using OSHA 300 Log and 301 Incident Report forms (29 CFR 1904.41). The forms must include information such as:

• The date the incident occurred
• The location or site of injury or illness
• The severity of the injury or illness
• Information about the impacted worker(s)
• How the injury or illness occurred

This applies only to organizations with 100 or more employees in the designated industries specified in Appendix B to Subpart E of 29 C.F.R. Part 1904. They are required to submit all information pertaining to the incident.

While collecting personal information about the employees, OSHA is ensuring compliance with GDPR by reducing access to personally identifiable information (PII) and safeguarding sensitive information. Employers must also be sensitive to privacy concerns and protect PII when electronically submitting the forms.

OSHA's Injury Tracking Application (ITA) can be submitted using one of the 3 following ways:

• Webform on the ITA
• Submit a CSV file to the ITA
• Use of an application programming interface (API) feed

The forms started being accepted since January 2, 2024, and all forms for the previous year must be submitted by March 2, 2024.

Benefits of the New Requirements

With the implementation of the new requirements, OSHA will have access to more accurate and extensive data that is specific to the illnesses and injuries in those organizations and industries. This will enable the agency to analyze the nature of hazards, capture trends related to injuries and illnesses, and assess their impact. These insights will help OSHA to create tailored programs for specific programs for reporting organizations and industries to address those challenges in a more focused manner to improve worker safety.

The data will also be made accessible to the public. This will enable peer organizations in the same industry, and other organizations facing similar case-specific injuries and illnesses, to make informed decisions for their organizations. Based on this data and trends, they can develop more meaningful safety management programs and make their workplace safe and healthy.

A third beneficiary is research organizations that will be able to draw insights from the visible patterns of injuries, illnesses, and hazardous conditions to recommend improved safety and healthy alternatives. This three-pronged benefit is expected to bring down the hazards and workplaces safer and healthier, thereby resulting in a reduction in occupational injuries and illnesses.

Challenges with the New Process

Compliance with new requirements may add administrative burdens and costs for the organizations that are mandated to submit the forms. They must create an account on the OSHA website, input the information in the required format, meet deadlines, and ensure PII criteria are met when submitting the forms.

The new requirements can also add to the safety burden on the organizations as they may become more liable to receive OSHA citations and fines in case of not complying with the new rule or submitting forms in time and in the prescribed manner. The risk of data errors further increases their challenges.

Opting for a cloud-based, end-to-end safety management solution such as ComplianceQuest can improve efficiency and data accuracy. ComplianceQuest’s Safety Solution automates the data collection process and provides enterprise-wide visibility, minimizing the lag between an incident’s occurrence and reporting. As a result, it also minimizes the delays in receiving the inputs from different locations, speeding up the data consolidation process.

As ComplianceQuest is already aligned with the OSHA requirements, the changes required to the system to meet the new requirements are minimized, accelerating the compliance process. Since it is cloud-based, even remote locations can access the updated system immediately, thereby standardizing the process across all locations.

To know more about the ComplianceQuest Safety Management Solution for incident reporting, visit: https://www.compliancequest.com/health-and-safety-incident-management-software/