Upload your OSHA 300A electronically by March 2 if your NAICS code begins with 23 and have 20 or more employees in an establishment. New additional requirements for 2024, if your NACIS code begins with 2381 and you have 100 or more employees in an establishment, you will also have to upload your OSHA 300 log (after removing data from column B) and the OSHA 301 for each recordable incident (after removing data from field 1, 2, 6 and 7).

Establishments that meet certain size and industry criteria are required to electronically submit injury and illness data from their OSHA Form 300A, 300 and 301 (or equivalent forms) annually to OSHA no later than March 2. OSHA collects this work-related injury and illness data through the听, which听also includes answers to听. Also, see the听听fact sheet, which听 explains how establishments can avoid submitting PII through the听

To determine whether you are required to submit this data, visit the听. This application only applies to establishments located in states under Federal OSHA jurisdiction. If your establishment is located in a听, please contact their OSH plan for guidance.

Background:

On July 21, 2023, the U.S. Department of Labor鈥檚 Occupational Safety and Health Administration issued its听, which undoes the ABC-supported provisions of the听听promulgated under the Trump administration and reprises the听. The final rule听went into effect听on Jan. 1, 2024, for certain employers and听OSHA intends to make much of the data it collects publicly available online.

In a听press release,听老牛影视announced its opposition to the final rule. 鈥淯nfortunately, the Biden administration is moving forward with a final rule that does nothing to achieve OSHA鈥檚 stated goal of reducing injuries and illnesses,鈥� said Ben Brubeck, 老牛影视vice president of regulatory, labor and state affairs. 鈥淚nstead, the final rule will force employers to disclose sensitive information to the public that can easily be manipulated, mischaracterized and misused for reasons wholly unrelated to safety, as well as subject employers to illegitimate attacks and employees to violations of their privacy.鈥�

• Establishments with 100 or more employees in certain听听are required to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year. They are also听required to include their legal company name when making electronic submissions to OSHA.
• Establishments with 20 to 249 employees in certain high-hazard industries will continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year.
• Establishments with 250 or more employees that must routinely keep records under OSHA鈥檚 injury and illness regulation will also continue to be required to electronically submit information from their Form 300A to OSHA once a year.
• The data must be electronically submitted through OSHA鈥檚听.

More Information:

• 老牛影视general counsel Littler Mendelson鈥檚听听of the final rule
• ABC鈥檚 members-only听archived webinar, 鈥淥SHA Developments Affecting the Construction Industry鈥�

In June 2022, 老牛影视submitted听comments听urging OSHA to withdraw the听proposed rule.

听For more information click here (). And while you are reviewing all this data, go ahead and submit your 2024 STEP Safety Management System data by clicking here ().