Reminder: OSHA Electronic Reporting Requirements Take Effect in 2024

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Beginning January 1, employers in certain industries will need to begin electronic filing of their Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report. The requirement applies to employers with 100 or more employees that belong to designated NAICS classification codes that the Occupational Safety and Health Administration (OSHA) considers to be high risk. Employers in certain industries with 20 or more employees will be required to submit the summary OSHA Form 300A annually. OSHA will make portions of this injury information publicly available to third parties.

OSHA is expected to announce the procedures for filing this information in early 2024. The initial filings will cover employee illness and injury information from 2023. Employers concerned about public release of this data should carefully review their workplace safety incidents and provide reports that comply with OSHA recordkeeping and reporting requirements, but exclude extraneous information. Only those injuries or illnesses deemed work-related and meeting the recording requirements should be included in these forms.

Employers that fail to comply with these requirements can be cited for violating OSHA’s reporting requirements. OSHA may also use this information for purposes of designating employers for focused safety inspections and for determining which employees to interview during inspections.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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