OSHA Form 300a Reporting Deadline and Other Recordkeeping Considerations
March 3, 2020 was the deadline for employers to electronically submit the required data from OSHA form 300A. Form 300A provides OSHA with a summary of all recordable work-related injuries and illnesses from the previous year and is to be filed through the electronic OSHA Injury Tracking Application (ITA). Employers can submit injury and illness data electronically.
What qualifies as an OSHA recordable event for purposes of the OSHA recordkeeping forms? OSHA defines a recordable event as follows:
- Any work-related fatality
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job
- Any work-related injury or illness requiring medical treatment beyond first aid
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
- There are also special recording criteria for work-related cases involving: needle sticks and sharps injuries; medical removal; hearing loss; and tuberculosis
Furthermore, employers should be mindful that on Jan. 25, 2019, OSHA removed the requirement for any employers to electronically submit information from the OSHA form 300 (log of reported injuries and illnesses) and OSHA form 301 (injury and illness incident report) to OSHA. Form 300A data is considered confidential commercial information and will not be released to the public. The final rule does not change the requirement to keep and maintain OSHA forms 300, 300A and 301 for five years.
While the requirement to record certain injuries and illnesses on OSHA forms 300, 301, and 300A applies to a great many employers, not all employers must comply. OSHA has provided some exemptions from the recording requirement. Those exemptions include the following scenarios:
- Employers with ten or fewer employees at all times during the previous calendar year are exempt from routinely keeping OSHA injury and illness records. OSHA’s revised recordkeeping regulation maintains this exemption.
- Establishments in certain low-hazard industries are also partially exempt from routinely keeping OSHA. OSHA provides at list of both exempt and newly covered industries.