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Risk in Context

How Will You Manage OSHA’s New Workplace Injury and Illness Reporting Rule?

Posted by James R Wright December 06, 2017

Although requirements and compliance timing for OSHA’s revised part 1904 recordkeeping and reporting rule have faced numerous issues and delays, the initial reporting deadline now looms and affected employers must be prepared.


Employers with an obligation to report Form 300A data electronically – approximately 500,000 establishments across the US – must submit their data through the Injury Tracking Application (ITA) on OSHA’s web site.

Originally launched on August 1, the ITA was temporarily shut down after breach concerns and a question over data security. OSHA said that no data was compromised and the site was re-launched.

Employers had hoped that the new administration would simply withdraw the electronic recordkeeping mandate after the delay, which is seen by some as burdensome on business. Instead, OSHA says that it is reviewing some provisions of the final rule. OSHA also indicated its intention to publish a notice of proposed rulemaking to reconsider, revise, or remove portions of the rule in 2018.


OSHA only requires that information from employers’ 2016 Form 300A Annual Summary be submitted electronically by December 15. More information may be required for large employers in 2018 and beyond, pending the outcomes of OSHA’s rulemaking proposal.

To meet the upcoming deadline, here are the steps affected organizations should take:

  1. Set up an account and create a password for the ITA, which OSHA estimates will take 10 minutes. You may want to review the ITA job aids and the API Technical Specifications first.
  2. Gather your Form 300A information. If your organization is made up of multiple establishments, exclude any establishments that are exempt from OSHA recordkeeping due to their peak employment headcount, NAICS industry classification, or state location.
  3. Choose from the three options to enter your Form 300A summary information on the ITA:
  • Manually enter data into a web form. This will probably be easiest if you have only one or two establishments, since the web form mirrors Form 300A.
  • Upload a CSV file to process single or multiple establishments at the same time. This will be more efficient if you are a large organization that centrally reports injury and illness information for all of your affected establishments.
  • Transmit automated recordkeeping systems’ data electronically via an application programming interface (API).

Staying on top of the changes to this and other OSHA rules will help you reduce your reporting risk, avoid fines, and build confidence in your organization’s approach to workplace safety.

Related to:  Marsh Risk Consulting

James R Wright

Jim is a senior vice president with Marsh Advisory.