Executive Summary: Beginning in January 2024, employers in certain high-hazard industries will be required to submit detailed information regarding recordable workplace injuries and illnesses using OSHA's new filing system called Injury Tracking Application (ITA).
Details of the New Requirement
Establishments with 100 or more employees in designated high-hazard industries must electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year's OSHA Form 300 Log and Form 301 Incident Report.
The ITA will begin accepting 2023 injury and illness data on January 2, 2024. The due date to complete the submission is March 2, 2024. The submission requirement is annual.
The data that must be submitted includes: the date, physical location, and severity of the injury or illness; details about the worker who was injured; and details of how the injury or illness occurred. Much of the information submitted will be posted on OSHA's public website.
It is estimated that more than 52,000 employers must start complying with the new rule. OSHA estimates that those employers will submit information on more than 750,000 injury and illness cases annually. Fewer than one percent of establishments in the country will be required to submit this additional data. However the data submitted by those establishments will comprise approximately 30 percent of all reportable occupational injuries and illnesses.
OSHA has posted significant guidance on its website, www.osha.gov, including written instructions and videos. Employers can answer five questions on the website to determine if their business must file a report. OSHA has issued Fact Sheets summarizing the new requirements (here) and protecting personal identifiable information (here).
States with their own federally approved worker safety programs must set up reporting mandates that are identical to or similar to the federal plan. The state plans will be able to use OSHA's website rather than setting up their own submission portals.
The Bottom Line
This new requirement affects a limited number of employers but has significant reporting requirements. Information submitted will be posted on OSHA's public website. As the ITA is new, there could be early technical problems with the portal. Covered employers may want to wait until closer to the March 2 deadline before submitting the required data.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
