Under 29 CFR 1904.41, the OSHA injury and illness electronic reporting regulation, many establishments must electronically submit information from their 2024 Work-Related Injury and Illness Forms (300, 300A, and 301) by March 2, 2025. OSHA considers an establishment to be a single physical location or facility where business is conducted, or where services or industrial operations are performed.
Who is Required to Submit Injury and Illness Data?
All establishments that are required to keep OSHA injury and illness records under 29 CFR Part 1904 must complete the OSHA Summary of Work-Related Injuries and Illnesses (Form 300A) each year even if no work-related recordable injuries or illnesses occurred. However, not every facility is required to electronically submit information from the Form.
Establishments must submit information from Form 300A only if they meet either of these criteria:
- Employed 250 or more employees at any time during the previous calendar year and are not in an industry indicated in the Exempt Industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904, or
- Employed 20-249 employees at any time during the previous calendar year and are in an industry included in Appendix A to Subpart E of 29 CFR Part 1904.
In addition, they must also submit data from their Log of Work-Related Injuries and Illnesses (Form 300) and from their Injury and Illnesses Incident Report (Form 301) if they have 100 or more employees and are in a designated industry listed in Appendix B to Subpart E of 29 CFR Part 1904.
Designated industries include food and beverage manufacturing; plastics and rubber products manufacturing; nonferrous metal production and processing; hospitals; and waste treatment and disposal facilities.
When determining if your facility is required to submit data to OSHA, every individual employed by the establishment at any time during the previous calendar year must be counted as one employee, including full-time, part-time, seasonal, and temporary workers.
How Should Injury and illness Data be Submitted?
OSHA provides a secure online Injury Tracking Application (ITA) that has the three submission options listed below.
- Manual entry of data via the ITA web form (note that OSHA recommends this option if submitting data for one or only a few establishments)
- Comma-separated values (CSV) batch file upload for processing submissions from multiple establishments
- Electronic data transmission via an application programming interface (API) for use with multiple establishments and a large amount of data to submit
Additional information on OSHA’s electronic reporting procedures and how to create an ITA account can be found on their ITA Information Webpage, including an ITA User Guide and Frequently Asked Questions.
For help determining if your facility is covered by OSHA’s electronic reporting regulation or for assistance with preparing and submitting the injury and illness data required for your organization, please contact us.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
