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OSHA’s Incident Report Procedure Change Rule

OSHA recently changed its rules for reporting injuries and illnesses this summer and the changes take effect on Jan 1, 2024.

Now more companies must report incidents electronically.

While this change is intended to lead to better statistics, it could also lead to more enforcement for companies that report injuries and illnesses.

In this article, we summarize the change, discuss who it affects, and what steps you might need to take to stay in compliance.

 

Who does it affect?

This change applies to companies with over 100 employees in High Hazard Industries.  High Hazard industries include, but are not limited to, all manufacturing, construction, utilities and wholesale trade industries.

 

Action items

If we already do periodic site visits to your facility as a part of our compliance management service, our project managers will check if you need to report more data. They will add reminders to your calendar. And they will help you make any needed process changes.

If you need help with OSHA logs, reporting, or figuring out which injuries to report, contact us at info@cdms.com. We look forward to assisting you.

 

CDMS Analysis

The changes introduced by OSHA in incident reporting procedures is the next step in OSHA’s plan to make all reporting electronic and to increase public awareness of workplace hazards. This will increase the annual workload of the employee who tracks the OSHA Logs by an estimated 1-2 hours per year.  It is not yet known if and how OSHA will report and make public this information.  Currently, OSHA inspections and deaths are reported.  If all injuries are to be reported publicly, it is likely that similar to stormwater, this data will be used in a legal context.  It is also expected that in time, potential employees will research these statistics when looking where to apply.

As we are preparing to implement these regulations, project managers are taking a renewed focus to injury prevention during the walkthroughs that are a part of the CDMS compliance management service.  From our experience, most injuries can be prevented from proper use of PPE and following procedures exactly.  It is important to take some time in the coming months to ensure leads and supervisors are aware of how their specific employees are confirming to company standards with regards to safety.

 

What Does the Rule Require?

The new OSHA ruling applies to establishments with 100 or more employees in designated high-hazard industries. These establishments are now required to electronically submit detailed information about each recordable injury and illness that was entered on their previous calendar year’s OSHA Form 300 Log and Form 301 Incident Report (29 CFR 1904.41). This information includes the date of the incident, its physical location, severity, details about the affected worker, and the circumstances surrounding the injury or illness. Additionally, each establishment must provide its legal company name when submitting this data.

This data was already required to be collected and retained, but now businesses are also required to electronically submit this information. The new rule does not affect the existing requirement for establishments with 20 to 249 employees in certain industries to electronically submit information from their OSHA Form 300A Annual Summary to OSHA once a year. Establishments with 250 or more employees in industries that routinely keep records must continue to electronically submit information from their OSHA Form 300A Annual Summary.

 

Why is OSHA Collecting this Data?

The primary goal of this rule change is to provide OSHA with access to establishment-specific, case-specific injury and illness data. This data will enable the agency to identify establishments with specific hazards, allowing them to take direct action through enforcement or outreach activities to address and mitigate these hazards, thereby enhancing worker safety and health. Furthermore, these data will facilitate a more in-depth analysis of injury trends in specific industries, processes, or hazards. By collecting and publishing data from Forms 300 and 301, OSHA aims to not only increase the available information for analysis but also produce more accurate statistics related to work-related injuries and illnesses. This will result in more detailed statistics on injuries and illnesses for specific occupations and industries.

In addition to benefiting OSHA, the rule change has a wider-reaching impact. Making establishment-specific injury and illness data accessible to the public enables employers, employees, potential employees, employee representatives, customers, potential customers, and the general public to make more informed decisions about workplace safety and health at a given establishment. Researchers will also have a more comprehensive dataset to identify patterns of injuries, illnesses, and hazardous conditions in workplaces. OSHA believes that this increased transparency will ultimately lead to a reduction in occupational injuries and illnesses.

 

How Will Electronic Submission Work?

To facilitate electronic submission, OSHA has introduced the Injury Tracking Application (ITA), a secure website that offers three submission options. First, users can manually enter data into a webform. Second, users can upload a CSV file to process single or multiple establishments at the same time. Finally, users of automated recordkeeping systems can transmit data electronically via an application programming interface (API).

Establishments subject to the new rule are required to submit the information from their completed Form 300 and Form 301 to OSHA by March 2nd of the year following the calendar year covered by the forms.