Phase 2 of OSHA’s new Electronic Submission of Injury and Illness Records comes due 01 July 2018 for the reporting of your OSHA 300 records for 2017. The text for the entire rule is found at [29 CFR 1904.41]
Phase 1 of the new e-Reporting rule required you to submit 2016’s reports electronically to OSHA by December of 2017. Hopefully, you got that done on time. But either way, Don’t Panic. The actual reporting process is simple, even if you have dozens of facilities.
Here are the steps in as brief an explanation as I could manage.
1. Determine Applicability – The first step is to determine if this requirement is applicable to your company. There are three “Brackets” of companies that must e-Report.
a. All companies with 250 employees or more (the upper bracket).
b. All companies that have 20 to 249 employees AND whose NAICS numbers are on a special list (the lower bracket).
c. Any individual company notified in writing by OSHA that they must e-Report.
Be Aware – OSHA has a particular way of counting employees. I call it the “at any time” method. For example, if your company usually has about 230 employees during 2017, but you bumped up to 250 or more for even one day, then you are in the upper bracket for Illness and Injury reporting. If your company averaged around 15 for 2017, but you had 20 or more on the payroll “at any time”, then you have been bumped up into the lower bracket for Electronic Reporting and you are subject to the new e-Reporting requirement.
“Employees”, by the way, are people that work for the company, “… whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers.”
The NAICS List – This is a list of specific industries that OSHA feels are worthy of more scrutiny because of the elevated level of risk to employee health and safety. So, if you have 20 to 249 employees during the reporting year and your company operates under one of the NAICS numbers, then you are required to e-Report. The NAICS list is included at the end of this article, and can also be found here: [THE NAICS LIST] .
2. Get Your OSHA 300A Form. To submit the information required by the e-Reporting rule, you will need to have your OSHA 300A form for 2017 on hand. All the information you need for the e-Report is on that form.
By the way, don’t forget to post that same form as required in [29 CFR 1904.32(b)(5)] – It needs to be displayed publicly where other employee notices are routinely posted.
3. Go To The Website. OSHA has created a specific place where you can submit your data. Go to the “Injury Tracking Application” page at [OSHA ITA Page]. Here you will find some instructions if this is your first visit. It is an unusually straightforward process, so it shouldn’t take long to figure out how to use it.
When you’re ready, click the blue “Launch ITA” button at the top right of the page. That will bring you to the login page. Click “Create an Account” if you don’t have one yet. That will require some very basic information on your facility and yourself. You will get an email asking to confirm the account.
Once you have an account established, you must enter some more specific information about your facility by clicking the “Create Establishment” button. You will have to give your facility a nickname if you have more than one location (ACME #217 for instance), then the official company name, and you will need your NAICS for this page. For each company location where employees work, you will have to create a separate establishment.
4. Data Entry. Now, you can enter the data from your OSHA 300A log. OSHA has 3 ways to do this.
a. You can manually fill in the data on the webform. Suitable if you just have one or two locations.
b. You can upload a CSV file with the required information for your location(s).
c. You can use your in-house or on-line recordkeeping software to upload the information, but those may not all work at this time.
After you have entered and carefully confirmed your data, then you submit the form to OSHA. You will get an email confirming the submission, but I recommend you also get a screenshot of the webpage showing the successful submission. Print these pages out and staple them together with your 300A form for permanent filing.
My hope is that this article has been helpful. I did it because my mission is to help the hyper-regulated business owners and managers of America deal with the burden of compliance with the OSHA, EPA and DOT regulations.
You are invited to take my Quick Compliance Assessment and see the 19 common compliance mistakes that most companies make. Go to [Compliance Assessment Link]
I may be contacted at (843) 599-0330 or by RHarvey@EchelonEHS.com .
THE LIST: Companies who operate under these NAICS codes and have from 20 to 249 employees are required to electronically report their annual records of injuries and illnesses to OSHA.
NAICS |
Industry |
11 |
Agriculture, forestry, fishing and hunting. |
22 |
Utilities. |
23 |
Construction. |
31-33 |
Manufacturing. |
42 |
Wholesale trade. |
4413 |
Automotive parts, accessories, and tire stores. |
4421 |
Furniture stores. |
4422 |
Home furnishings stores. |
4441 |
Building material and supplies dealers. |
4442 |
Lawn and garden equipment and supplies stores. |
4451 |
Grocery stores. |
4452 |
Specialty food stores. |
4521 |
Department stores. |
4529 |
Other general merchandise stores. |
4533 |
Used merchandise stores. |
4542 |
Vending machine operators. |
4543 |
Direct selling establishments. |
4811 |
Scheduled air transportation. |
4841 |
General freight trucking. |
4842 |
Specialized freight trucking. |
4851 |
Urban transit systems. |
4852 |
Interurban and rural bus transportation. |
4853 |
Taxi and limousine service. |
4854 |
School and employee bus transportation. |
4855 |
Charter bus industry. |
4859 |
Other transit and ground passenger transportation. |
4871 |
Scenic and sightseeing transportation, land. |
4881 |
Support activities for air transportation. |
4882 |
Support activities for rail transportation. |
4883 |
Support activities for water transportation. |
4884 |
Support activities for road transportation. |
4889 |
Other support activities for transportation. |
4911 |
Postal service. |
4921 |
Couriers and express delivery services. |
4922 |
Local messengers and local delivery. |
4931 |
Warehousing and storage. |
5152 |
Cable and other subscription programming. |
5311 |
Lessors of real estate. |
5321 |
Automotive equipment rental and leasing. |
5322 |
Consumer goods rental. |
5323 |
General rental centers. |
5617 |
Services to buildings and dwellings. |
5621 |
Waste collection. |
5622 |
Waste treatment and disposal. |
5629 |
Remediation and other waste management services. |
6219 |
Other ambulatory health care services. |
6221 |
General medical and surgical hospitals. |
6222 |
Psychiatric and substance abuse hospitals. |
6223 |
Specialty (except psychiatric and substance abuse) hospitals. |
6231 |
Nursing care facilities. |
6232 |
Residential mental retardation, mental health and substance abuse facilities. |
6233 |
Community care facilities for the elderly. |
6239 |
Other residential care facilities. |
6242 |
Community food and housing, and emergency and other relief services. |
6243 |
Vocational rehabilitation services. |
7111 |
Performing arts companies. |
7112 |
Spectator sports. |
7121 |
Museums, historical sites, and similar institutions. |
7131 |
Amusement parks and arcades. |
7132 |
Gambling industries. |
7211 |
Traveler accommodation. |
7212 |
RV (recreational vehicle) parks and recreational camps. |
7213 |
Rooming and boarding houses. |
7223 |
Special food services. |
8113 |
Commercial and industrial machinery and equipment (except automotive and electronic) repair and maintenance. |
8123 |
Dry-cleaning and laundry services. |