OSHA Initiates Enforcement Program for Completion of OSHA Forms 300, 301 and 300A - The Edge from the National Association of Landscape Professionals

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OSHA Initiates Enforcement Program for Completion of OSHA Forms 300, 301 and 300A

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) proposed amendments to its occupational injury and illness recordkeeping regulations. OSHA released the “pre-publication” version of its proposed rulemaking (NPRM) intended to “Improve Tracking of Workplace Injuries and Illnesses.”

OSHA is initiating an enforcement program that identifies employers who failed to submit Form 300A data through the agency’s Injury Tracking Application (ITA).  

Currently, annual electronic submissions are required by establishments with 250 or more employees. Establishments with 20-249 employees classified in specific industries with historically high rates of occupational injuries and illnesses are also required to keep OSHA injury and illness records.

OSHA is proposing to require additional electronic reporting of workplace injury and illness and to post that submitted data on a public website after identifying and removing information that reasonably identifies individuals directly. 

According to the NPRM, OSHA is proposing to require establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year.

Establishments with 20 or more employees in certain industries would continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year. NAICS 5617 (services to buildings and dwellings) fall under “certain designated industries” and therefore these changes pertain to our members.

OSHA claims the rule changes will empower it to improve workplace safety and health by:

•            allowing OSHA to use its resources more effectively by better enabling the agency to identify workplaces where workers are at greatest risk from specific hazards, and to target its compliance assistance and enforcement efforts accordingly;

•            improving the ability of employers to compare their own injury and illness data on hazards with the data from similar establishments in the same industry;

•            improving the ability of stakeholders to make more informed decisions using recent establishment-specific, case-specific, injury/illness information; and

•            improving research on occupational safety and health.

NALP will continue to monitor the issue and provide updates if and when necessary. Further information is available at the OSHA website here: https://www.osha.gov/sites/default/files/OSHA-RK-Forms-Package.pdf