Ditchmen • NUCA of Florida Ditchmen - July 2023 | Page 7

the injuries / illnesses resulted in lost time or restricted duty . Form 301 is the Injury and Illness Incident Report , which provides even more detail about specific injuries and / or illnesses reported on Form 300 , including employee addresses , dates of birth , and treatment information .
Now , after January 1 , 2024 , OSHA ’ s new rule requires employers with 100 or more workers in the listed industries to annually provide information from their Forms 300 and 301 in addition to the information from Form 300A . OSHA has stated that employers do not need to provide employee names , addresses , or health care providers . However , OSHA has not yet specified how the electronic submission will be set up to address potential employee privacy concerns . of submission , this can result in a recordkeeping citation . Now OSHA ’ s injury tracking application ( ITA ) will begin accepting the 2023 data on January 2 , 2024 , and it is due by March 2 , 2024 . Employers should be reviewing their records now to ensure they are accurate and determine whether this new rule applies to their establishments . This includes not only federal OSHA but all state plans as well .
This new rule , which was first brought by the Obama administration in 2016 but later rolled back by the Trump administration in 2019 , reinstates requirements to submit data electronically to OSHA . Also , in 2016 , several industry groups challenged the rule in federal courts ; however , it is not clear whether this rule will be challenged again .
Employers with the required number of employees in each establishment ( and certain industries ) should have already been submitting their Form 300A by March 2 of every year . Failure to submit the form is tracked by OSHA every time an inspection is opened at an establishment , and if the employer does not retain proof
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