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OSHA announces all states now affected by e-reporting requirement

Requirement to report applies, even if the state hasn’t adopted OSHA final rule

Posted April 30, 2018

OSHA announced a major change in its collection of 2017 workplace injury and illness data. Employers with covered establishments located in all states must submit their 300-A Summary data by the July 1, 2018, deadline — not just employers in states that have adopted OSHA’s final rule requiring the submissions.

OSHA has notified the affected states about the change and posted a notice on its Injury Tracking Application website.

Until now, OSHA exempted employers with establishments located in OSHA state-plan states that have not adopted the Improve Tracking of Workplace Injuries and Illnesses final rule. These states include California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming.

Covered employers are those with establishments that meet the following criteria:

  • They are already keeping OSHA injury and illness records (OSHA 300 Log, 300-A Summary, and 301 Incident Reports); and
  • They have 250 or more employees; or
  • They have 20-249 employees and are listed by NAICS code in Appendix A to Subpart E.

OSHA says there is no retroactive requirement to submit data for Calendar Year 2016.

The new stance comes after a review of the requirements put in place by the final rule. OSHA determined that Section 18(c)(7) of the Occupational Safety and Health Act, and relevant OSHA regulations pertaining to State Plans, require all affected employers to submit injury and illness data in the Injury Tracking Application (ITA) online portal, even if the employer is covered by a State Plan that has not completed adoption of their own state rule.

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