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OSHA Changes Form 300/301 Reporting Rules. What You Need to Know

February 11th, 2019

What has Changed?

OSHA recently rescinded the requirement for employers with 250 or more employees to electronically submit information from OSHA Forms 300 and 301 to the agency each year.

What are Forms 300 and 301?

Form 300 is the log of individual work-related injuries and illnesses and Form 301 is the individual injury and illness incident report. (Form 300A contains the summarized site data from the Forms 300 and 301.)

Why the Change?

OSHA stated that the change has come in response to concern that sensitive information of individuals in the reports could have been publicly disclosed under the Freedom of Information Act.  According to OSHA:

“This rule will better protect personally identifiable information or data that could be re-identified with a particular worker by removing the requirement for covered employers to submit their information from Forms 300 and 301.”

Does The Information Still need to be Reported to OSHA?

Yes! Employers will still need to summarize work-related illnesses and injuries. This reporting will continue to be collected on OSHA Form 300A by all companies with more than 10 employees and submitted electronically by March 2 each calendar year for companies with more than 250 employees (and for OSHA designated “High Risk” companies with 20 or more employees).  While the reporting requirements have changed, it is still vital that you continue to maintain Forms 300 and 301 at the worksite for at least 5 years for OSHA inspection.

Are There Other Requirements I Need to Follow?

The rule also still requires you to comply with the electronic reporting rule’s anti-retaliation provisions. Unchanged from earlier rules, employers also must continue to post a copy of Form 300A in a conspicuous place within the workspace.

In addition, employers must still report to OSHA within 8 hours any worker fatality and report any amputation, loss of an eye, or hospitalization of a worker within 24 hours.

The new final rule also amends the recordkeeping regulation to require covered employers to submit their Employer Identification Numbers (EIN) electronically along with their summarized injury and illness data submissions—a change OSHA says is intended to better coordinate data collection and reduce potential duplicative reporting  The first compliance deadline for the submission of EINs is March 2, 2020; employers will not be required to submit their EINs with the Form 300As that are due March 2, 2019.

When Does Is This Happening?

February 25, 2019, 30 days after the final rule’s publication in the Federal Register on January 25.

Need to Know More?

Click here to contact one of HRP’s Environmental Health and Safety experts. Out health and safety professionals include those recognized and certified as Certified Industrial Hygienists (CIH), Certified Hazardous Materials Managers (CHMM), Certified Safety Professionals (CSP),) Associate Safety Professionals (ASP), and Radiation & Laser Safety Officers (RSO and LSO). HRP has been helping private and public organizations meet complex regulatory compliance obligations for over 30 years. Our team members understand that you require practical solutions with minimal operational impact. Our focus is to develop safe, cost-effective solutions which balance compliance and risk reduction with capital cost of investment, production and business continuity, quality and ongoing operational costs.

Jim Darrow, Ph.D., CHMM, FMP, Senior EH&S Manager at HRP Associates, Inc.

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