Understanding OSHA’s electronic recordkeeping requirements


Occupational Safety and Health Administration (OSHA)'s rule “Improve Tracking of Workplace Injuries and Illnesses" requires establishments with 250 or more employees, as well as establishments with 20 or more employees in high-risk industries, to electronically submit their 300A Form data to OSHA annually by March 2.

This article reviews the steps employers must take to comply with the rule and submit your data electronically to OSHA using the agency's Injury Tracking Application (ITA). If you're new to OSHA recordkeeping, check out our Ultimate OSHA Recordkeeping guide for the basics.

Man and woman with laptop

What data must organizations submit electronically to OSHA in 2021?

All covered establishments are required to electronically submit 300A form data for the previous calendar year by March 2.

Initially, the final rule had also required establishments with 250 or more employees to electronically submit additional injury and illness data from Forms 300 and 301 by this July 1 deadline. However, on January 24th, 2019, OSHA published a new final rule to Protect Worker Privacy that rescinded the requirement to electronically submit Forms 300 and 301 for establishments with 250 or more employees. OSHA cited risk of disclosure of this sensitive information, costs to collect the data, and the burden of reporting the data on these forms as unjustifiable given uncertain benefits.

The table below further clarifies that only Form 300A data will be due by the rule’s annual submission deadline.

Submission Year Data Collected in Calendar Year Establishments with 250 or More Employees Establishments with 20-249 Employees Submission Deadline
2020 2019 Form 300A Form 300A March 2, 2020
2021 2020 Form 300A Form 300A March 2, 2021
2022 2021 Form 300A Form 300A March 2, 2022


What else should I know about the new final rule to Protect Worker Privacy?

The new final rule also requires establishments to electronically submit their Employer Identification Number (EIN) along with their Form 300A injury and illness data, likely to assist in the enforcement of the rule.

It's important to keep in mind that the final rule to Protect Worker Privacy has not eliminated the requirement for employers to fill out and keep records of 300 and 301 forms, it has just eliminated requirements to submit this data to OSHA electronically. You should still keep records of these forms and should be ready to present them to a compliance officer as part of an OSHA inspection.

Policies for Employers under State Plans

On April 30, 2018, OSHA issued a press release correcting an implementation error that impacts the compliance obligations of employers in state-plan states.

This correction stated that covered establishments in all states must now submit Form 300A data using OSHA’s ITA portal, even if an establishment is covered by a State Plan that has not completed adoption of their own state rule. OSHA also clarified that state government and local government establishments operating under State Plans are required to electronically submit Form 300A data if they otherwise meet the criteria for compliance.

The majority of states operating under a State Plan have since adopted an identical version of the rule, including:

  • Arizona;
  • Connecticut;
  • Illinois;
  • Indiana;
  • Iowa;
  • Maine;
  • Michigan;
  • Minnesota;
  • Nevada;
  • New Jersey;
  • North Carolina;
  • South Carolina;
  • Tennessee;
  • Vermont;
  • and Wyoming

However, as of January 1, 2020, a few state plans still have yet to implement the electronic recordkeeping rule, including Maryland, Utah, and Washington.

What does this mean for employers in state plans that have not adopted the rule?

OSHA is still requiring employers in all state plans to submit their data. However, employers should be aware that Federal OSHA does not have authority to compel employers with establishments in those states to submit data, and neither federal OSHA nor the state OSH agencies can cite a violation under 29 C.F.R. 1904.41, because that regulation does not apply to employers in State Plan States.

Getting Started with OSHA's Injury Tracking Application

For establishments that will be submitting their data for the first time, it’s simple and easy to create an ITA account. However, to avoid setting up duplicate accounts for your company (and to avoid the duplication of data submissions), it’s best to coordinate with your team and clearly designate which individual(s) will be responsible for using the ITA and creating an account for your organization.

For establishments that have complied with the rule in previous years, submitting your Form 300A data by the March 2, 2020 deadline should be straightforward, as safety professionals will already have set up their organization’s ITA account, and will be familiar with the portal.

As a refresher, though, you'll first begin by logging into the ITA portal directly from OSHA's website.

After you have logged in, you’ll be taken to the ITA homepage, where the number of days left before the submission deadline passes is helpfully displayed towards the top of the page.

OSHA Electronic Recordkeeping ITA Home Page

Submitting Your OSHA 300A Data Manually

Your organization can choose between two methods to submit its recordkeeping data: manually or through a batch submission process.

To enter your data manually, you first need to add your establishments to the application by creating profiles for them. Once you have set up your establishments, you will then be able to enter and submit OSHA 300A data for each one.

To help you track your progress, the ITA's homepage provides a status summary of your created establishments that have no data, establishments with data added, and establishments for which data was submitted.

OSHA Electronic Reporting Manually Add 300A Summary

Submitting Your OSHA 300A Data using a CSV File

For a quicker and simpler electronic reporting submission process, the ITA also offers the option to upload a CSV file containing 300A data for many establishments at once.

This method is ideal for organizations that need to submit data for multiple establishments.

When you’ve prepared and submitted your file, the batch file page will display a message that your file was successfully uploaded.

If you’re unable to upload the file that you’ve browsed for, we recommend checking the file type, as only CSV file formats will be accepted.

OSHA ITA New Reporting Requirement Upload CSV File

Lessons Learned Using OSHA's ITA

1. Pay close attention to the emails that are sent from the application

When you initially upload your CSV file, you will instantly receive an email from the ITA system that your file is being processed. This is not the same as a confirmation that your 300A data has been submitted!

The ITA needs time to process the file, checking for any errors or missing data. Fortunately, the application is pretty good about telling you what went wrong, and you’ll receive an email with details if anything in your CSV file needs to be corrected.

A sample email that we received with our fake testing data is below.

OSHA ITA Reporting Email Error

If your data does not contain any errors, you'll then receive an email confirmation that your submission was sent successfully.

2. You can't have decimals in your CSV file's "Average Number of Employees" column

Our team didn’t receive an email with an error message provided about this issue and only discovered the problem through trial and error. While it might seem obvious that you can’t have 100.9 employees, if you don’t round to the nearest whole number, there will be consequences.

The biggest concern with this issue is that if there is a single decimal anywhere in the Average Number of Employees column, the CSV file will be corrupted and nothing will process.

If you are uploading a batch file with multiple establishments, make sure to do some due diligence before you upload.

3. Manual Data Entry Takes Time and Effort

The process to manually submit your 300A data, or even manually prepare a CSV file for a batch data upload, is very simple, but can be tedious and time-consuming.

As a friendly reminder, organizations using Vector EHS Management Software to track workplace incidents can quickly and easily generate a CSV file of your 300A data with a few clicks of a mouse.

Using safety software such as Vector EHS Management to create your CSV file will not only save valuable time and resources but also help you to catch any errors or missing information that your file contains before you submit your data to OSHA.

If you’re looking to avoid the headaches of data entry, consider signing up for a demo of Vector EHS management today.

What happens if an employer failed to submit their 300A data by the first filing deadline?

OSHA has issued a memorandum outlining the agency’s enforcement policy of the electronic recordkeeping rule. As part of any onsite inspection, OSHA’s compliance officers will inquire whether an establishment has electronically filed its 300A form.

If the compliance officer learns that the establishment was required to electronically submit its 300A form and failed to do so, OSHA will issue an other-than-serious citation for failing to comply with the regulation. OSHA may also pursue a full recordkeeping audit if there is evidence of potential systemic recordkeeping issues.

The agency has announced that general industry employers who fail to electronically submit Form 300A data will be selected at random for OSHA inspections. OSHA will also target employers with high DART (Days Away, Restricted or Transferred) rates as part of this initiative. OSHA will use these data to create new programmed inspection lists for use by its Area Directors and State Plan states.

OSHA hopes the program will boost electronic recordkeeping compliance.

If you weren't able to submit your data by the deadline in previous years, this year is your chance to comply.

Warehouse managers and worker talking in a large warehouse

The Bottom Line: Recommendations for Employers

OSHA’s enforcement memorandum makes it clear that the agency is committed to the electronic collection of 300A Form information.

It may help to take the time now to familiarize yourself with the ITA and explore tools like Vector EHS Management that can make compliance even easier.

Learn how OSHA recordkeeping software can help streamline your 300A form data collection and submission process.

Clare Epstein is Vice President of EHS and RIsk Solutions at Vector Solutions and oversees Vector EHS Management Software. Numerous organizations throughout the United States utilize Vector EHS Management’s Incidents module to record, track, and analyze a variety of safety incidents; create accurate regulatory reports, including OSHA 300, 300A, and 301 logs; and prepare their 300A form data for electronic submission.

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