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OSHA Introduces Key Changes with "29 CFR 1904: OSHA's New Injury Recordkeeping E-Sub

Did you hear about OSHA's new change?

In a move towards enhanced transparency and efficiency, the Occupational Safety and Health Administration (OSHA) has implemented a significant change with the introduction of the "29 CFR 1904: OSHA's New Injury Recordkeeping E-Submission Rule." Effective immediately, this rule brings about key changes in injury recordkeeping procedures, impacting a wide range of businesses.


Key Changes:

1. Electronic Submission Requirement: The most notable change is the mandatory electronic submission of injury and illness records to OSHA. Covered establishments are now required to submit their Form 300A summaries annually through the Injury Tracking Application (ITA) on OSHA's website.


2. Increased Transparency: OSHA aims to improve data accuracy and enhance transparency by making injury and illness data publicly accessible. This move aligns with OSHA's commitment to providing valuable insights into workplace safety.


3. Applicability to Larger Establishments: While the previous rule applied primarily to high-risk industries and larger establishments, the new regulation expands its reach. Businesses with 250 or more employees are mandated to electronically submit their Form 300A summaries. Additionally, businesses in specific high-risk industries with 20-249 employees are also subject to this requirement.



Businesses Affected:

Not every business falls within this reporting obligation. Only a subset of establishments must submit data from their OSHA injury and illness recordkeeping forms to OSHA. Establishments under Federal OSHA can use the ITA Coverage Application to check if electronic reporting is obligatory. For State Plan establishments, direct communication with the State Plan is recommended.


Establishments meeting these conditions are exempt from electronically reporting to OSHA. Note that these criteria apply at the establishment level, not the entire firm.

  1. The establishment's highest employment in the preceding year was 19 or fewer, regardless of its industry.

  2. The establishment operates in an industry on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of size.

  3. The establishment had peak employment between 20 and 249 individuals in the previous year AND its industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.



Preparing for the Change:

1. Electronic Recordkeeping Systems: Businesses should evaluate their current recordkeeping systems to ensure they can facilitate electronic submission seamlessly. Take advantage of a digital compliance mangement system like SMS360, which fills out your OSHA 300 and 300-A forms for you with the click of a button



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2. Training and Awareness: Ensure that relevant personnel are aware of the new requirements and are adequately trained to handle electronic submission processes. This includes training on the proper completion of Form 300A summaries.


3. Review of OSHA Forms: Periodically review OSHA Forms 300, 300A, and 301 to ensure accurate and up-to-date recording of workplace injuries and illnesses. This is crucial for maintaining compliance and submitting precise data to OSHA.


4. Stay Informed on Updates: OSHA may release additional guidance or updates related to the new rule. Businesses should stay informed about any changes and adapt their processes accordingly.


In conclusion, OSHA's "29 CFR 1904: OSHA's New Injury Recordkeeping E-Submission Rule" ushers in a new era of electronic transparency and recordkeeping. Businesses must promptly adjust their practices to ensure compliance, embracing the benefits of enhanced data accuracy and improved workplace safety.

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