Additional OSHA electronic reporting requirements are coming back.
By Mike Harper | 02/19/2022
In 2016, toward the tail end of the Obama administration, OSHA issued a rule that required employers to submit all of the OSHA forms electronically. Up to this point the employer had only been required to provide an annual summary, the 300A, by February 1st. This form contains only the numbers from the 300 log. The 300 log contains the employee's name, location of the accident and a brief description of the injury, as well as number of lost and/or restricted workdays, etc. Form 301 is called the Injury and Illness Incident Report and contains detailed information regarding the employees health care until they are able to return fully to work.
The new rule applied to employers with 250 or more employees, as well as those with 20-249 employees in certain [high risk] industries. These submissions were all to be done through OSHA's Injury Tracking Application (ITA) website. The Trump administration reduced the scope of the required reporting to only apply to the annual 300A. Enter the Biden administration, which has drafted a new Executive Order (EO) expanding the reporting requirements back to what was originally defined under Obama.
The proposals that OSHA is putting forward to fulfill this EO include requirements to submit the 300 Log of Work-Related Injuries and Illnesses, and Form 301. These reporting requirements would apply to the same group of employers currently subject to the 300A electronic reporting. Companies in states that have incorporated their own State Plans will also be required to participate in the electronic reporting.
The current state of electronic reporting, where only the 300A is required to be completed, once a year, is not particularly onerous. Today, most people manually enter the required information. There are also provisions for uploading with an Excel spreadsheet. A few software solutions also provide a direct connection to the ITA. In today's world, there isn't much difference in effort between these options.
Now fast-forward to 300 Log and 301 reporting requirements. This now becomes a really big deal. Safety Managers and HR are already running at beyond maximum capacity. Adding a reporting requirement that, most likely, has a much higher volume of data, now causes issues. Not only from a time perspective, but also in terms of data. Even though you are allowed and expected to capture and maintain employee injury and illness records, you don't want that data/information floating around the organization in any more places than is absolutely necessary. So what's going to be the best way to deal with this issue, taking time efficiency and data security both into account?
Option 1 - Hand Enter
I'm sure ITA will have the option to hand enter 300 Log and 301 data, just as you can with the 300A today. This kind of manual re-entry of data is time consuming and prone to mistakes. You also need to have people available (not on vacation) that know how to perform this entry, and what to enter, to ensure timely recording.
Option 2 - Upload File
If you are using software that produces Excel files, this is better. You reduce the time required for manual entry, as well as eliminate the possibility of data error. However, you do have the possibility of submitting the wrong files, etc. as this process is done manually. Additionally, you now have files that are "somewhere" in your organization. What is your process for creating, retaining, submitting and removing these files? Given the sensitive employee information contained in them, you still need to have just a small, core group of people that would be able to see this data, run the process of submitting to the ITA.
Option 3 - Web Services Integration
This is a computer-to-computer transfer of data that only requires permission to press a button. If implemented properly, once the initial information is entered into the software linking it to your ITA account, you eliminate data entry errors, time spent manually re-entering data, as well as reduce your risk by not having to produce files with sensitive employee information. This is the type of solution you will want to ensure you have in place when these electronic reporting requirements become mandatory.
Feel free to contact us for any questions you may have regarding ITA integration and/or how we make it easier with Simple Safety Coach!
UPDATE: We've published another blog with additional details that have been released.