OSHA Publishes Updated Rule on Electronic Reporting of Workplace Injuries and Illnesses

On July 17th, OSHA released a publication announcing changes to the recordkeeping standard which impacts the electronic reporting through OSHA’s Injury Tracking Application (ITA).  These new changes increase the number of employers who are now responsible for reporting their injury and illness data annually as well as the amount of data that is required to be submitted for certain organizations.  OSHA estimates this will create additional reporting requirements for an estimated 50,000 organizations when they submit their electronic records in 2024.

Who must submit their data electronically?

The requirement to electronically report injury and illness data to OSHA depends on the size of the establishment and the type of work being performed.  For OSHA, “establishment” refers to a single facility or location. 

Previous Reporting Requirements:

Any establishment with 250 or more employees at any time during the calendar year are required to report their OSHA Form 300A Annual Summary.
Any establishment in a designated “high risk” industry with 20 – 249 employees at any time during the calendar year are required to report their OSHA Form 300A Annual Summary.

Updated Reporting Requirements:

Any establishment with 250 or more employees at any time during the calendar year are required to report their OSHA Form 300A Annual Summary.

If the establishment classifies as “high-risk”, additional information will have to be reported per below.


Any establishment in a designated “high risk” industry with 100 or more employees at any time during the calendar year must submit detailed information including their OSHA 300 Log, OSHA 300A Summary, and the Form 301 for each incident that occurred.
Any establishment in a designated “high risk” industry with 20 – 99 employees at any time during the calendar year are required to report their OSHA Form 300A Annual Summary.
All establishments reporting data are required to include their legal company name when making electronic submissions.

When does the data need to be submitted?

Electronic reporting submissions are due no later than March 2nd of the following year. In other words, employers’ data from their OSHA 300, 301, and 300A forms for 2023 will need to be submitted to OSHA’s Injury Tracker Application by March 2nd, 2024.

There is a secure website to submit the data electronically.  You can create an account using the following hyperlink –  Injury Tracking Application | Occupational Safety and Health Administration (osha.gov).

You can check out additional frequently asked questions regarding OSHA’s electronic reporting rules such as what’s an NAICS code and how establishments work here: https://www.assuranceagency.com/blog-post/osha-electronic-reporting-webinar-q-a

If you have specific questions about your company and reporting requirements, please reach out to your MMA Risk Consultant.