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Injury and Illness Reporting and Posting Requirements - MOSH Training and Education

Injury and Illness Recording Requirements went into effect January 1, 2024 New

Injury and Illness Submission begins January 2, 2024, and ends March 2, 2024
Injury Tracking Application (ITA)
Electronic Injury and Illness Recording Requirement
Employers post summary of injuries and illnesses recorded in 2023 (posting period: Feb1 to Apr 30, 2024)

Electronic Injury and Illness Reporting Requirement:

OSHA is reminding certain employers to submit their 2023 OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) data by March 2, 2024.

Please note not all employers are required to submit this information. There are conditions whereby an employer must provide this data:

  1. If your establishment had 250 or more employees during the previous calendar year, and your establishment is in an industry required to keep OSHA injury and illness records on an ongoing or routine basis, you must provide these data online; or
  2. If your establishment had 20 or more employees but fewer than 250 during the previous calendar year, and you are in one of the identified high-hazard industries found in Appendix A to Subpart E, in 29 CFR 1904.41(a)(2) of the OSHA recordkeeping regulation, you must submit your OSHA log summary data. List of high-hazard industries.
  3. Only establishments with 100 or more employees in designated industries are required to submit case-specific information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report.
    1. Establishments that had a peak employment of 100 or more employees during the previous calendar year meet this size criteria.
    2. The designated industries are listed in Appendix B to Subpart E of 29 C.F.R. Part 1904.
    3. One way to determine if your establishment(s) is required to report these data is by using our ITA Coverage Application.
    4. The requirements apply to establishments covered by Federal OSHA, as well as establishments covered by states with their own occupational safety and health programs (i.e., State Plans).
  4. To improve data quality, establishments are required to include their legal company name when making electronic submissions to OSHA from their injury and illness records.

Employers who meet the conditions for electronic reporting may begin to submit their calendar year 2023 occupational injury and illness summary data beginning on January 2, 2024 and will have until March 2, 2024. If the submission due date of March 2 has passed, establishments that meet the reporting requirements and failed to do so must still submit the required recordkeeping data through the ITA and can do so until December 31.

Follow this link to enter the data - OSHA’s Injury Tracking Application.

OSHA’s electronic reporting requirement is completely independent of, and has no bearing on, the annual injury and illness survey reporting to the U.S. Bureau of Labor Statistics.

Frequently Asked Questions:

  1. Who is responsible for filling out the OSHA injury and illness recordkeeping forms?

    Employers with 10 or fewer employees in the previous calendar year are exempt from completing OSHA injury and illness recordkeeping forms. However, if the number of employees exceeds 10 at any point during the year, the requirement may apply. Full-time, part-time, temporary, and seasonal workers must all be counted. This exemption is based on the total employment of the company, not individual establishments. For instance, if a company operates two establishments, one with 5 employees and the other with 7, both establishments must complete the forms because the total company employment surpasses 10. Apart from the small employer exception, certain industries are also exempt unless OSHA, the Bureau of Labor Statistics (BLS), or a state agency authorized by OSHA or the BLS requests them in writing. For instance, restaurants, banks, and medical offices don't need to complete the forms. For a full list, check the see Partially Exempt Industries.

  2. What forms are required to be filled out?

    Employers must complete three forms: OSHA forms 300 and 301 are updated continuously to record injuries and illnesses as they happen. At the end of the year, OSHA Form 300A is filled out to summarize recordable cases. Equivalent forms can be used if they contain identical data elements and are as easily readable as OSHA forms.

  3. What constitutes an injury or illness, and which cases are considered work-related?
    OSHA defines an injury or illness as an abnormal condition or disorder, encompassing cuts, fractures, sprains, skin diseases, respiratory conditions, and even subjective symptoms like aches or pain. Exposures without signs or symptoms are not considered injuries or illnesses and should not be recorded on OSHA forms. For instance, if an employee is exposed to chlorine without displaying any symptoms, even if they receive preventative medical treatment, it wouldn't be recorded on the Log.

    Cases caused, contributed to, or significantly aggravated by events or exposures at work are considered work-related for OSHA recordkeeping. This includes injuries and illnesses occurring at the workplace or where the employee is situated as part of their job. If work plays any role in the injury or illness, it is deemed work-related for OSHA recordkeeping. For a list of activities that are not work-related refer to section 1904.5(b)(2)

  4. What is OSHA’s definition of a recordable injury or illness?

    OSHA defines a recordable injury or illness as any work-related fatality, injury, or illness that leads to loss of consciousness, time away from work, restricted work activity, or job transfer. Additionally, it includes any work-related injury or illness requiring medical treatment beyond first aid. This also encompasses diagnosed cases of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums. Furthermore, there are specific recording criteria for cases involving needlesticks and sharps injuries, medical removal, hearing loss, and tuberculosis in the workplace.

  5. How long should the forms be kept on file?

    Forms should be kept on file for 5 years following the year to which they pertain. Update Form 300 with any changes during this period. Completed forms shouldn't be sent to OSHA but must be available to employees, former employees, their representatives, and OSHA officials upon request. Confidentiality should be maintained while promoting occupational safety and health. Refer to sections 1904.35 and 1904.40 for access provisions.

For additional information, contact:

Division of Labor and Industry

MOSH Consultation Services
Maryland Occupational Safety and Health (MOSH)
10946 Golden West Drive, Suite 160
Hunt Valley, Maryland 21031
MOSH Outreach/Compliance Assistance