New Expanded OSHA ITA Reporting due March 2; Uses 2023 OSHA 300 log

Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses on the OSHA 300 log. OSHA logs need to be maintained for 5 years and OSHA 300A (summary) must be posted from February 1 to April 30 annually. Here are a few basics about OSHA 300 Logs, and how to use the OSHA log to complete the newly updated online Injury Tracking Application (ITA).

OSHA defines recordable injuries or illnesses (to be added to the OSHA 300 log) as:

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.

First-aid cases are excluded from the OSHA 300 logs. Here are some common first-aid situations:

  • Using a non-prescription medication at nonprescription strength.
  • Tetanus shots.
  • Cleaning, flushing or soaking wounds on the surface of the skin.
  • Using wound coverings such as bandages, Band-Aids™, gauze pads, etc… or using butterfly bandages or Steri-Strips.
  • Using hot or cold therapy.
  • Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc…
  • Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.
  • Using eye patches.
  • Removing foreign bodies from the eye using only irrigation or a cotton swab.
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means.
  • Massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
  • Drinking fluids for relief of heat stress.

OSHA’s Injury Tracking Application (ITA) now requires increased online reporting by certain establishments with 100 or more employees in high-hazard industries, which were already required to submit summary information on the OSHA Form 300A Annual Summary. A new 2023 rule change now mandates these employers submit injury specific information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report (or first report of injury). This expanded reporting requirement is based on employees and industry classification of an establishment.

You must submit 300A data if your establishment meets one of the following criteria:

  1. Large employers (250 or more employees) and is not in an industry listed in the Exempt Industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904 or
  2. Small employers (20-249 employees) and is in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904.

Additionally, you must submit 300/301 data if your establishment(s) has 100 or more employees and is in an industry listed in Appendix B to Subpart E of 29 CFR Part 1904.

ITA deadline is March 2. You can start submitting your 2023 injury and illness data on January 2, 2024. The due date to complete this submission is March 2, 2024. The submission requirement is annual and you must complete the submission of the previous year’s injury and illness data by March 2 of each year.

If you are an employer required to submit data to OSHA under the ITA, here is How to create an ITA account with OSHA.

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