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OSHA Drops Requirement to Electronically Submit OSHA Forms 300 and 301

Jan 31, 2019

In what it calls a move to protect worker privacy, OSHA has issued a final rule that eliminates the requirement for establishments with 250 or more employees to electronically submit information from OSHA Form 300 (used to record work-related injuries and illnesses) and OSHA Form 301 (injury and illness incident report) to OSHA each year.

These establishments must continue to maintain those records on-site, and OSHA will obtain them as needed through inspections and enforcement actions. In addition to reporting required after severe injuries, establishments will continue to submit information from their Form 300A.

"By preventing routine government collection of information that may be quite sensitive, including descriptions of workers’ injuries and body parts affected, OSHA is avoiding the risk that such information might be publicly disclosed under the Freedom of Information Act," the agency states. "This rule will better protect personally identifiable information or data that could be reidentified with a particular worker." 

OSHA is also amending the recordkeeping regulation to require covered employers to electronically submit their Employer Identification Number with their Form 300A information. This will make the data more useful and could reduce duplicative reporting burdens on employers, OSHA says.

Collection of calendar year 2018 OSHA Form 300A began on Jan. 2, 2019. The deadline for electronic submissions is March 2, 2019.

Robert Miller

In addition to reporting required after severe injuries, establishments will continue to submit information from their Form 300A.

The above is confusing. You might clean it up and state Electronic recording is required only for 300a forms of 250 or more and still required 20 to 249 in hazard industries also need to submit the 300A.

You might also state failure to submit will put you on a target list.

Dean Myers
I find it a little strange that Federal Agencies are still required to submit this information per 29 CFR 1960.72; I guess our data isn't subject to the risk of exposure via FOIA request.

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