Important OSHA Policies & Rulemaking Update on Four Key Issues
By Monica Munin
1 . Final Rule Expanding Submission Requirements for Injury & Illness Data
OSHA ’ s final rule requiring new submissions of injury and illness data for certain employers in high-hazard industries takes effect on January 1 , 2024 . The rule will require certain employers to electronically submit injury and illness information they must already maintain to OSHA directly . OSHA indicated in its press release that it intends to publish some of the data it collects from these submissions on its website “ to allow employers , employees , potential employees , employee representative , current and potential customers , researchers and the general public to use information about a company ’ s workplace safety and health record to make informed decisions .” OSHA has also indicated that “ it will use this data to intervene through strategic outreach and enforcement to reduce worker injuries and illnesses in high-hazard industries .” The new rule requires covered establishments with one hundred ( 100 ) or more employees to electronically submit information from their Form 300-Log of Work-Related Injuries and Illnesses , and Form 301-Injury and Illness Incident Report to OSHA once a year . This submission is in addition to the obligation to submit Form 300A-Summary of Work-Related Injuries and Illnesses . The final rule retains the current requirements for electronic submission of information on Form 300A for establishments with 20-249 employees in certain high-hazard industries and employers with 250 or more employees in industries that must routinely keep OSHA injury and illness records .
4 DITCHMEN • NOVEMBER 2023