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OSHA Q1 Updates

06 Feb

Update Applicable to:Effective date
All covered employers – see details belowAnnual OSHA Form 300A Workplace – February 1, 2024
Electronic Reporting Form 300 A – March 2
Electronic Submission Form 300 & 301 – March 2

What happened?

A breakdown of key OSHA compliance updates for employers.

What are the details?

These updates are as follows:

  1. Summary of Work-Related Injury and Illnesses: 

  • Covered employers: Employers that had 11 or more workers at any point in 2023. 
  • Compliance Item: Submit Form 300A, Summary of Work-Related Injury and Illnesses.
  • Period to report: From February 1, 2024, to April 30, 2024.
  • Exception(s): Low-risk industry or 10 or fewer employees.
  • Employee count: Entire company.
  • Notices: Post Form 300A, certified by a company executive, in a conspicuous location.

  1. Electronic Submission of Form 300A:
  • Covered employers: Employers that had 250 or more workers in the prior calendar year (2023) or with 20 to 249 workers if they are in a high-risk industry (see the list here).
  • Compliance item: Submit Form 300A using online Injury Tracking Application (ITA).
  • Period: until March 2, 2024.
  • Exception(s): 

a. Establishment was 19 or fewer employees, regardless of establishment industry.
b. Low-Risk industry, regardless of employees working at the establishment. 
c. Establishment between 20 and 249 employees and is not on the High-Risk industry list.

  • Employee count: workers at physical location (not entire company) and industry classification.
  • Notices: Post Form 300A, certified by a company executive, in a conspicuous location.

  1. High-Risk industries with 100 or more workers new requirement: submit electronically Form 300 Log and 301 Incident Report (with Form 300A Annual Summary, which they should be already submitting).

Other considerations: 

  • Employers covered by a State Plan that has not yet adopted its own state rule must also use the ITA to send data electronically.
  • Establishments covered by Federal OSHA can use the ITA Coverage Application to determine if they are required to electronically submit their injury and illness information to OSHA. 
  • Establishments covered by an OSHA-approved State Plan should directly contact their State Plan.

Business Considerations 

  • Remember that employers that must comply with the regulations must also maintain the records on the worksite for at least 5 years. 
  • Employers that do not need to comply with the regulations can inspire themselves to implement policies and practices to have a safer workplace. 
  • There are states that have their own state plan (like California or Utah), so be mindful of them. Check this map for the information here.
  • Determine if the new rules are applicable to you and create or update your current policies that address recordkeeping and reporting to OSHA.


Source References

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This communication is intended solely for the purpose of conveying information. The present post might incorporate hyperlinks directing readers to websites managed by third-party entities. The inclusion of any links within this communication is meant to serve as points of reference and could encompass opinion articles from various law firms, articles from HR associations, official websites, news releases, and documents of government agencies, and other relevant third-party sources. Vensure has no authority over these external websites and bears no responsibility for their content. Furthermore, Vensure does not endorse the materials present on these websites. The contents of this communication should not be interpreted as legal advice or as a legal standpoint concerning specific facts or scenarios. Nor should it be deemed an exhaustive compilation of facts potentially pertinent to federal, state, or local laws. It is strongly advised that employers solicit legal guidance from an employment attorney when undertaking actions in response to any legal updates provided. This is due to the possibility of future alterations occurring in federal, state, and local laws, regulations, as well as the directives and guidelines issued by governing agencies. These changes may transpire at any given time, potentially rendering certain portions of the content within this update void or inaccurate.

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