Rancho Mesa's Alyssa Burley and Media Communications & Client Services Specialist Lauren Stumpf discuss OSHA’s final rule on electronically submitting injury and illness records.
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OSHA’s Injury Tracking Application (ITA) Website
Director/Host: Alyssa Burley
Guest: Lauren Stumpf
Producer/Editor: Megan Lockhart
Music: "Home" by JHS Pedals, “News Room News” by Spence
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Transcript
Alyssa Burley: Hi, this is Alyssa Burley with Rancho Mesa’s Media Communications and Client Services Department. Thank you for listening to today’s top Rancho Mesa news brought to you by our safety and risk management network, StudioOne™.
Welcome back, everyone. My guest is Lauren Stumpf, Media Communications and Client Services Specialist with Rancho Mesa. Today, we're going to talk about OSHA’s final rule on electronically submitting injury and illness records. Lauren, welcome to the show.
Lauren Stumpf: Hi Alyssa, thanks for having me.
AB: For many of Rancho Mesa’s clients, especially those in the construction and landscape industries, they’re already required to submit their injury and illness data from the Form 300A annually via the federal OSHA’s website. However, there have been some recent changes that expand the requirements.
So, Lauren, what data is now needed to be submitted?
LS: So, like you mentioned, OSHA is updating its occupational injury and illness recordkeeping regulation to require certain employers to electronically submit injury and illness information to OSHA. This is something that employers are already required to keep under the recordkeeping regulation, but in previous years they did not have to submit.
Specifically, OSHA is amending its regulation to require establishments with 100 or more employees in certain designated industries, like our construction trades and landscapers, to electronically submit additional information from their OSHA Forms 300 and 301, once a year. This is in addition to the data on the Form 300A.
AB: And this might concern some people with regard to employees’ personal information being made public.
LS: Well, OSHA says they will not collect employee names or addresses, names of health care professionals, or names and addresses of facilities where treatment was provided, if the treatment was provided away from the worksite – this is all found on the Forms 300 and 301.
AB: So, what stays the same in the amended rule?
LS: Establishments with 20 to 249 employees in certain industries will continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year.
And all establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation will also continue to be required to electronically submit information from their Form 300A to OSHA on an annual basis.
AB: So, has anything else changed?
LS: OSHA is also updating the NAICS codes used in appendix A, which designates the industries required to submit their Form 300A data, and is adding appendix B, which designates the industries required to submit Form 300 and Form 301 data. This document is available online at federalregister.gov and on govinfo.gov.
Establishments will be required to include their company name when making electronic submissions to OSHA. OSHA intends to post some of the data from the annual electronic submissions on a public website after identifying and removing information that could reasonably be expected to identify individuals directly, such as individuals’ names and contact information.
AB: Okay, and we’ll make sure there is a link to appendix A and appendix B in the episode notes, so listeners can easily access both of those. When does the final rule become effective?
LS: The final rule becomes effective on January 1, 2024.
AB: So, how can Rancho Mesa clients document their OSHA data?
LS: In our RM365 HRAdvantage™ portal, clients can document their incidents, generate the OSHA 300 and 300A, along with the CSV file for uploading the 300A data to federal OSHA’s website. Currently, the 300 and 301 data will need to be manually entered into OSHA’s Injury Tracking Applicatio, ITA, website.
AB: Alright so, Lauren, if listeners have questions about how to complete their OSHA Logs in the HR portal, who should they contact?
LS: Clients can reach out to their client services coordinator or anyone at Rancho Mesa and we’ll get you in touch with the right person.
AB: Alright well Lauren, thanks for joining me in StudioOne.
LS: Thanks for having me, Alyssa.
AB: This is Alyssa Burley with Rancho Mesa. Thanks for tuning in to our latest episode produced by StudioOne™. For more information, visit us at ranchomesa.com and subscribe to our weekly newsletter.
