Between February 1st and April 30th, 2020, all employers covered by the recordkeeping regulation must post a hard copy of their 2019 OSHA 300A Summary in a common area of their workplace that employees can readily access and observe it. For employers of certain sizes and industries, an additional requirement of electronic reporting has been added with a deadline of March 2nd, 2020.
The employers’ responsibilities in regard to OSHA Logs and electronic reporting are based on the number of employees and type of industry, as described below:
OSHA logs and electronic reporting NOT required
Companies with 10 or fewer employees (all establishments combined) or those who are on the Partially Exempt Industries list do not need to complete 300/300A/301 forms or electronically submit them. The Partially Exempt Industries list applies even if the establishment has more than 10 employees.
OSHA logs AND electronic reporting required
The following employers must track recordable workplace injuries on their 300/300A/301 forms and must submit information from their 2019 300A Summary by March 2nd, 2020.
- Establishments with 250 or more employees in any industry covered by the recordkeeping regulation
- Establishments with 20-249 employees in certain high-risk industries
OSHA logs required, electronic reporting NOT required
The following employers must track recordable workplace injuries on their 300/300A/301 forms and maintain those records as required, but are not subject to the new electronic submission requirements:
- Establishments with 10-20 employees in any industries covered by the recordkeeping regulation
- Establishments with 20-249 employees not on the high-risk industry list
If you fall into an electronic reporting category
OSHA has provided a secure website and injury tracking application to submit data. The Injury Tracking Application (ITA) is accessible from the ITA launch page. Required 2019 submissions are due on or before March 2nd, 2020.
You can perform this task on your own or subscribe to our OSHA Log Review and Submission service by contacting John Valentine.
Visit the OSHA Recordkeeping and Reporting page at https://www.osha.gov/recordkeeping/