OSHA Injury & Illness Reports Will Change for Some Workplaces in 2024
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Revised workplace injury and illness reporting regulations, including more burdensome submission requirements for some larger establishments in specific industries, take effect on January 1, 2024.
We broke down all aspects of the rule in a Lion News feature this week.
For workplaces of all sizes subject to OSHA regulations, knowing which injury and illness cases to record and what information (if any) your workplace must submit each year is crucial to compliance.
Who's Required to Record and Report Injuries?
All employers must report any workplace incident that results in death, hospitalization, amputation, or eye loss [29 CFR 1904.39].?
In general, OSHA requires establishments with more than 10 employees to keep a log of new, work-related injury and illness cases (OSHA Form 300—Log of Work-Related Injuries and Illnesses).
In addition to recording these incidents, some employers must submit an annual summary of injury/illness data (Form 300A—Summary of Work-Related Injuries and Illnesses).
New OSHA Reporting Rules for 2024
OSHA's new Final Rule? for injury and illness reporting continues to require two categories of business establishments to electronically submit an annual summary of injury and illness data (OSHA Form 300A):
What's new for next year? OSHA will now require the following establishments to submit information from three OSHA injury and illness forms—Form 300A, Form 300, and Form 301 (Injury and Illness Incident Report):
The newly added Appendix B lists industry sectors that were already included on Appendix A and demonstrate an especially high rate of work-related injuries and illnesses.
Not all of the information included on these forms is required. Employee name and address, for example, are not required from Form 300 or 301.
OSHA "intends for March 2, 2024 to be the first submission deadline for the new information required to be submitted under this rule."??That means employers must submit the required information from injury and illness forms covering this calendar year (2023) before March 2, 2024.
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Achieve or Maintain Compliance for March 2024
Here is what workplaces of different sizes can do now to ensure ongoing compliance with OSHA injury and illness reporting regulations before the next reporting submission deadline on March 2, 2024:
100 or more employees (and listed in the new Appendix B)
The newly added Appendix B to Part 1904, Subpart E lists industry sectors that were already included on Appendix A and demonstrate an especially high rate of work-related injuries and illnesses.
If your industry sector is listed, you are now required to submit details from Forms 300 and 301 in addition to the annual summary (300A).
20–249 employees (and listed in Appendix A)
Appendix A to Part 1904 Subpart E lists industry sectors that OSHA has designated as having a higher risk of workplace injuries and illnesses. Employers with 20 to 249 employees in industries listed on Appendix A must continue to submit the annual summary of injury and illness data (Form 300A).
Note: The Final Rule also updates Appendix A to reflect the 2017 version of NAICS industry sector codes.
250 or more employees (and required to keep records)
You must continue to submit the annual summary of injury and illness data (OSHA Form 300A). OSHA has reversed course on this provision since March 2022, when they proposed to remove it. In the end, the rule remained in place.
Secondly, check the list of industry sector NAICS codes in the newly added Appendix B to 29 CFR Part 1904, Subpart E. If your industry sector is listed, you are now required to submit details from Forms 300 and 301 in addition to the annual summary (300A).
Employers reported 2.2 million recordable injury cases in 2021, 6.3% more than the year before.
The number of recordable illness cases reported to OSHA decreased substantially in 2021, driven largely by a steep drop (38%) in respiratory illness cases. (Source: Bureau of Labor Statistics ).
*The National Safety Council (NSC) has estimated that a worker is injured on the job in America every 7 seconds (Source: InjuryFacts.NSC.org ).