News and Updates
Category: OSHA 300A
A Guide to Submitting 2023 OSHA Logs
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, communication
OSHA Site Specific Targeting (SST)
The Site-Specific Targeting (SST) plan is OSHA’s main site-specific programmed inspection initiative for non-construction workplaces that have 20 or more employees. OSHA will generate inspection lists based on elevated Days Away, Restricted, or Transferred (DART) rates for 2019, and sites with upward trending rates for the three-year range of 2017-2019. They will also identify a random sample of establishments that did not provide them the required 2017, 2018, and 2019 Form 300A data. To verify data accuracy and quality control, OSHA also intends to include a random sample of low-rate establishments from the 2019 data. 1. High-Rate Establishments The SST plan selects individual establishments for inspection based on 2019 Form 300A data. Since average DART rates vary widely among industries, OSHA will set one DART rate for manufacturing and a different DART rate for non-manufacturing as objective selection criteria. 2. Upward Trending Establishments OSHA will identify establishments with rates above their industry’s national average in 2017 that have continued to trend upward in both 2018 and 2019 and continue to remain above their industry’s national average. 3. Low-Rate Establishments To verify the reliability of the Form 300A data reported to OSHA, the agency will generate a random sample of establishments with low DART rates using the 2019
OSHA 300A Submissions
It’s time for employers to submit and post their OSHA 300A. Here are some pointers to guide you through the process. More resources can be found on OSHA.gov. Electronic Submission: Go to https://www.osha.gov/injuryreporting/ Click the red “Launch injury tracking application” button on right and follow the instructions Details: Who - Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and/or illnesses. Visit the OSHA website for list of “certain industries”. What - Covered establishments must electronically submit information from their OSHA Form 300A. When - In 2022, covered establishments must submit information from their completed 2021 Form 300A by March 2. How – OSHA provides a secure website that offers three options for data submission. First, users can manually enter data into a web form. Second, users can upload a CSV file to process multiple establishments at the same time. Last, users of automated recordkeeping systems will have the ability to transmit data electronically via an API (application programming interface). View the CSV instructions Download a CSV file template Download a CSV sample file View the API technical
