2017 Injury and Illness Data Reporting
By: Kelly D. Ogle, BSDH, MIOP, CMPM, CHOP®
Director of OSHA and HIPAA Services
OSHA’s 2016 final rule to Improve Tracking of Workplace Injuries and Illnesses called for employers with 250 or more employees to begin submitting their 300 Log and 301 Incident Report information in 2018. The purpose is to help OSHA use its enforcement and compliance assistance resources more effectively.
At this time, OSHA’s ITA website is not accepting these forms. The Agency plans to propose a rule to reconsider, revise, or remove provisions of the final rule, which may include the collection of the data from Forms 300 and 301.
Meanwhile, establishments with 250 or more employees are only required to provide their 2017 Form 300A summary data. Establishments with 20-249 employees in certain high hazard industries are also covered by the requirement.
The Injury Tracking Application (ITA) is accessible from the ITA launch page, where businesses are able to provide the Agency their 2017 OSHA Form 300A information. The date by which certain employers are required to submit to OSHA the information from their completed 2017 Form 300A is July 1, 2018.
In future years, the reporting deadline will be March 2 of each year.
Establishments in state-plan states that were not required to submit their information to OSHA last year should check with their state to see if electronic reporting requirements will be adopted in 2018.
Most private medical and dental offices in states under Federal OSHA are not required to keep these records. Not only do they fall beneath the threshold of 250 employees, but they are also in the “partial exemption” group.
Partial List of Partially Exempt Industries
NAICS Code Industry Description
6211 – Offices of Physicians
6212 – Offices of Dentists
6213 – Offices of Other Health Professionals
6214 – Outpatient Care Centers
6215 – Medical and Diagnostic Laboratories