It’s time to post and electronically submit your OSHA logs - and this year, submission requirements will impact far more U.S. employers. We discussed this in detail when the rule was finalized in July 2023. Effective January 1, 2024, OSHA will require employers with over 100 employees in certain high hazard industries to complete electronic records submissions of Forms 300 and 301, in addition to Form 300A. These are records that covered employers should already be keeping, but previously have not been required to submit. The impacted industries include (but aren’t limited to) retail, wholesale, performing arts, manufacturing, farming, and grocers. Our safety team agrees that the fastest, easiest way to find out your company’s submission requirements is to use this ITA Coverage Application. Enter your company’s NAICS code and employee count, and it will confirm which logs should be submitted. As a general guide:

• 20-249 employees and on this list must submit 300A
• 100 or more employees and on this list must submit the 300A, 301 and 300 log. 

Employee count is “per establishment,” not entire corporation size. So, what is OSHA’s definition of an “establishment?”
An establishment is a single physical location where business is conducted, or where services or industrial operations are performed. For activities where employees do not work at a single physical location - such as construction, transportation, communications, electric, gas, and sanitary services, and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc., that either supervise such activities or are the base from which personnel carry out these activities. 
 
Electronic Submission:  

• Go to the Injury Tracking Application on the OSHA website. 
• Click the blue “Launch the ITA” button and follow the instructions
• In 2024, covered establishments must electronically submit information from their completed 2023 Form 300A by March 2, 2024.
• OSHA provides a secure website that offers three options for data submission. Users can manually enter data into a web form, upload a CSV file to process multiple establishments at the same time, or users of automated recordkeeping systems will have the ability to transmit data electronically through an API.

Please be aware that if you’re submitting data for just one or for a small handful of establishments, it is much easier to enter the data using the web forms rather than creating and uploading a CSV file. Simply click on the "Create Establishment" button and fill out the two web forms for each establishment and you're finished. If you already provided your establishment information for a previous collection (year), you only need to click on “View establishment list,” select the already entered establishment and provide the new 300A summary data.

Employers must post the 300A in the work place between February 1st – April 30th, 2024. Posting location must be a prominent area like breakroom, time clock, etc., where employees can observe the form.