October 20, 2017
Update as of December 15, 2017: OSHA has extended the deadline to submit electronic reporting of injury and illness data from December 15, 2017 to December 31, 2017. Read on to learn how to electronically submit your data before the new compliance date.
Back in May 2016, OSHA issued a final rule to help improve the tracking of workplace injuries and illnesses. As part of this new rule, certain employers, based on size and industry, are required to electronically submit their injury and illness data directly to OSHA’s Injury Tracking Application (ITA) for public disclosure.
While the end goal of OSHA’s final rule is to encourage companies to do more to prevent work-related injuries and illnesses and to better inform the public about workplace hazards, the final rule has caused a wave of uncertainty among health and safety professionals. If you’re like many EHS leaders we’ve talked to lately, you may be wondering: which forms do I need to submit? What’s the best way to do it? How long is this going to take me? How do I even get started?
To help answer these questions and more, I recently hosted a webinar with the National Safety Council on this topic and have also put together a primer below to help you get started. Here you'll find everything you need to know to submit your injury and illness data to OSHA before the new December 31, 2017 compliance deadline.
How do I know if I need to electronically submit my company’s injury and illness information?
Let’s start with the basics. OSHA’s electronic reporting requirements are based on the size of the establishment, not the firm, and injury and illness records are maintained at the establishment level. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments.
My organization has more than 250 employees. Do I need to submit?
If you’re in an industry that’s covered by OSHA’s recordkeeping regulation and you have establishments with 250 or more employees, you will need to electronically submit OSHA Forms 300A for your 2016 data. Moving forward, establishments with 250+ employees will need to submit Forms 300A, 300, and 301 when reporting for the 2017 data year and beyond.
My organization has less than 250 employees. Do I need to submit?
If you have establishments with 20-249 employees and you’re in an industry that falls under an applicable NAICS code (to determine your NAICS code, go here), you will only need to electronically submit information from OSHA Form 300A for 2016 and subsequent years.
I have establishments with 20-249 employees and I know my NAICS code but I’m still unsure if I need to submit. How can I check?
To see if you need to submit your injury and illness summary or if you’re exempt, check out this NAICS code list from OSHA.
To recap, here's a helpful chart that outlines who needs to submit what and when:
How can I submit my illness and injury information to OSHA?
There are three ways to submit your data to OSHA’s Injury Tracking Application. Below are the pros of each method:
Manual Data Entry – exactly what it sounds like: typing your data directly into OSHA’s ITA. This is a good option for EHS professionals with a small number of establishments or for those who don’t have an electronic recordkeeping system. If you have many establishments, this option probably isn’t for you as it can be time consuming to set them up in the ITA.
Import File – a good choice for organizations with multiple establishments that want to save time by batch uploading information. Simply import your CSV files within OSHA’s ITA. If there are any issues with your file, OSHA will identify them to you via e-mail and you can go in and manually correct them.
API – if you’re already using an application for electronic recordkeeping, this is a great option for a streamlined submission process. All you need to do is get a token from the ITA so your system and OSHA’s can directly talk to each other. Most third party vendors will be able to support this.
OSHA Electronic Submission Checklist: What to Do Before December 15, 2017
With the December 15th deadline to electronically submit your injury and illness data just around the corner, here’s a 7-point checklist to help you prepare:
- Define your establishments and determine what you’re going to report.
- Set up an account in the ITA testing sandbox. This should take less than 10 minutes.
- Determine your submission method – are you going to go manual, batch upload CSV files or use the API functionality?
- Review the data that you’re going to submit – pull together all your data from 2016 and make sure everything’s accurate.
- Do a test submission to OSHA’s ITA sandbox to make sure everything goes smoothly. You don’t have to use your company’s actual information. Using identifiers like “Company123” will suffice. Testing simply helps you make sure your files work and that you receive the confirmation emails from OSHA.
- Monitor for regulatory developments. As OSHA regulations can change, make sure you stay up to date with the agency’s latest news. However, have a plan in place and be prepared to submit before December 31st.
- Submit! Plan to submit in late November/early December, but don’t wait until the very last day. There will likely be a heavy load on the system on December 30th and things could be slower than expected.
For a complete walk through of how to electronically submit your injury and illness data before the new December 15th compliance deadline, watch our webinar with the National Safety Council.
About the Author
Melissa Kephart, CSP is a Client Service Consultant for Cority providing consultation to clients in the areas of implementation planning, work process review, training, and sustaining support. Prior to working with Cority, Melissa was a management consultant providing safety and industrial hygiene expertise to senior-level government managers. Melissa has extensive experience in custom OHS software development, agency-level safety program management, and Voluntary Protection Programs.More Content by Melissa Kephart, CSP