OSHA Update: Deadline Extended to Provide Electronic Submission of Injury and Illness Records

2016 OSHA 300A forms will now be due on Dec. 15, 2017

OSHA has extended the deadline to electronically submit injury and illness records to the agency. Employers will be required to upload their 2016 OSHA 300A form by Friday, Dec. 15, 2017, which was extended from the previous deadline of Dec. 1. The Injury Tracking Application (ITA), the system allowing for electronic submission of forms to the agency, is accessible here.

OSHA electronic reporting requirements are based on the size of the establishment or physical location, not the firm. A firm may have more than one establishment. Establishments with 250 or more employees are required to submit all necessary injury and illness records electronically using one of three data submission options provided by OSHA.

  1. Manually enter data into a web form.
  2. Upload a CSV file to process single or multiple establishments at the same time.
  3. Transmit data electronically via an application programming interface (for users of automated recordkeeping systems).

Establishments with 20 to 249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses are also required to submit injury and illness records electronically. However, these covered establishments are only required to electronically submit information from OSHA Form 300A. A full list of these industries can be found here.

The new reporting requirements became effective on Jan. 1, 2017, and will be phased in over a two-year period. All covered establishments must submit information from their completed 2016 Form 300A by Dec. 15, 2017.

In 2018, covered establishments with 250 or more employees must submit information from all completed 2017 forms (300A, 300 and 301) by July 1, 2018, and covered establishments with 20 to 249 employees must submit information from their completed 2017 Form 300A by July 1, 2018.

Beginning in 2019 and every year thereafter, covered establishments must submit the information by March 2.