The Occupational Safety and Health Administration (OSHA) has announced changes effective January 1, 2024 that expand the scope of the injury data employers must electronically submit and which industries must comply.

Update to electronic submission requirements for employers

As of January 1, all establishments with 100 or more employees at any time during the previous calendar year that are in one of the high-hazard industries listed below are required to submit case-specific information from their OSHA 300 and 301 forms, as well as their OSHA Form 300A annual summary.

Establishments with 20 to 249 employees in certain industries, and all establishments with 250 or more employees that are required to keep OSHA 300 records, will continue to be required to electronically submit information from their OSHA 300A annual summary to OSHA once a year.

Employers can access the Injury Tracking Application (ITA) by March 2 each year to submit the required information from the prior calendar year to OSHA.

Currently, employers haven't been submitting information from their OSHA 300 and 301 forms annually. Two groups of establishments were required to submit information from their OSHA 300A annual summary to OSHA once a year:

  • Establishments with 250 or more employees in industries required to routinely keep OSHA injury and illness records.
  • Establishments with 20-249 employees in certain designated industries.

Key takeaways

  • This update applies to employers who fall under Federal OSHA, as well as approved state plans.
  • OSHA plans to publish some of the data collected on its website for the public to use to make informed decisions about a company's workplace safety and health.
  • OSHA will identify and remove information that could reasonably be expected to identify individuals directly, such as individuals' names and contact information.
  • Establishments will be required to include their legal company name when making electronic submissions to OSHA.
  • Many employers use an insurance form such as a worker's compensation First Report of Injury or Illness form instead of the OSHA 301. It's important that the form has the same information, is readable and is completed using the same instructions as the OSHA form it replaces, or supplements the insurance form by including any additional information required by OSHA.
  • In addition to ensuring the OSHA forms are accurately completed, it will be increasingly important to strategize on how to minimize instances of recordable injury and illnesses in the workplace. With the increased visibility to OSHA, as well as employees and the public, it's anticipated that the quality and accuracy of the data will improve, to avoid violations. OSHA intends to use the collected information to more accurately identify patterns and trends to more effectively allocate its enforcement and compliance assistance resources, as well as develop effective workplace safety standards. Employers, employees and employee representatives will be able to use the collected data to improve workplace safety and health and increase access to the data.

The full list of affected industries is outlined by OSHA below and is organized by NAICS code.*

NAICS Industry
1111 Oilseed and Grain Farming
1112 Vegetable and Melon Farming
1113 Fruit and Tree Nut Farming
1114 Greenhouse, Nursery, and Floriculture Production
1119 Other Crop Farming
1121 Cattle Ranching and Farming
1122 Hog and Pig Farming
1123 Poultry and Egg Production
1129 Other Animal Production
1133 Logging
1141 Fishing
1142 Hunting and Trapping
1151 Support Activities for Crop Production
1152 Support Activities for Animal Production
1153 Support Activities for Forestry
2213 Water, Sewage and Other Systems
2381 Foundation, Structure, and Building Exterior Contractors
3111 Animal Food Manufacturing
3113 Sugar and Confectionery Product Manufacturing
3114 Fruit and Vegetable Preserving and Specialty Food Manufacturing
3115 Dairy Product Manufacturing3116Animal Slaughtering and Processing
3116 Animal Slaughtering and Processing
3117 Seafood Product Preparation and Packaging
3118 Bakeries and Tortilla Manufacturing
3119 Other Food Manufacturing
3121 Beverage Manufacturing
3161 Leather and Hide Tanning and Finishing
3162 Footwear Manufacturing
3211 Sawmills and Wood Preservation
3212 Veneer, Plywood, and Engineered Wood Product Manufacturing
3219 Other Wood Product Manufacturing
3261 Plastics Product Manufacturing
3262 Rubber Product Manufacturing
3271 Clay Product and Refractory Manufacturing
3272 Glass and Glass Product Manufacturing
3273 Cement and Concrete Product Manufacturing
3279 Other Nonmetallic Mineral Product Manufacturing
3312 Steel Product Manufacturing from Purchased Steel
3314 Nonferrous Metal (except Aluminum) Production and Processing
3315 Foundries
3321 Forging and Stamping
3323 Architectural and Structural Metals Manufacturing
3324 Boiler, Tank, and Shipping Container Manufacturing
3325 Hardware Manufacturing
3326 Spring and Wire Product Manufacturing
3327 Machine Shops; Turned Product; and Screw, Nut, and Bolt Manufacturing
3328 Coating, Engraving, Heat Treating, and Allied Activities
3331 Agriculture, Construction, and Mining Machinery Manufacturing
3335 Metalworking Machinery Manufacturing
3361 Motor Vehicle Manufacturing
3362 Motor Vehicle Body and Trailer Manufacturing
3363 Motor Vehicle Parts Manufacturing
3366 Ship and Boat Building
NAICS Industry
3371 Household and Institutional Furniture and Kitchen Cabinet Manufacturing
3372 Office Furniture (including Fixtures) Manufacturing
3379 Other Furniture Related Product Manufacturing
4231 Motor Vehicle and Motor Vehicle Parts and Supplies Merchant Wholesalers
4233 Lumber and Other Construction Materials Merchant Wholesalers
4235 Metal and Mineral (except Petroleum) Merchant Wholesalers
4239 Miscellaneous Durable Goods Merchant Wholesalers
4244 Grocery and Related Product Merchant Wholesalers
4248 Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers
4413 Automotive Parts, Accessories, and Tire Stores
4422 Home Furnishings Stores
4441 Building Material and Supplies Dealers
4442 Lawn and Garden Equipment and Supplies Stores
4451 Grocery Stores
4522 Department Stores
4523 General Merchandise Stores, including Warehouse Clubs and Supercenters
4533 Used Merchandise Stores
4543 Direct Selling Establishments
4811 Scheduled Air Transportation
4841 General Freight Trucking
4842 Specialized Freight Trucking
4851 Urban Transit Systems
4852 Interurban and Rural Bus Transportation
4853 Taxi and Limousine Service
4854 School and Employee Bus Transportation
4859 Other Transit and Ground Passenger Transportation
4871 Scenic and Sightseeing Transportation, Land
4881 Support Activities for Air Transportation
4883 Support Activities for Water Transportation
4889 Other Support Activities for Transportation
4911 Postal Service
4921 Couriers and Express Delivery Services
4931 Warehousing and Storage
5322 Consumer Goods Rental
5621 Waste Collection
5622 Waste Treatment and Disposal
6219 Other Ambulatory Health Care Services
6221 General Medical and Surgical Hospitals
6222 Psychiatric and Substance Abuse Hospitals
6223 Specialty (except Psychiatric and Substance Abuse) Hospitals
6231 Nursing Care Facilities (Skilled Nursing Facilities)
6232 Residential Intellectual and Developmental Disability, Mental Health, and Substance Abuse Facilities
6233 Continuing Care Retirement Communities and Assisted Living Facilities for the Elderly
6239 Other Residential Care Facilities
6243 Vocational Rehabilitation Services
7111 Performing Arts Companies
7112 Spectator Sports
7131 Amusement Parks and Arcades
7211 Traveler Accommodation
7212 RV (Recreational Vehicle) Parks and Recreational Camps
7223 Special Food Services


*"Improve Tracking of Workplace Injuries and Illnesses," Federal Register, 21 Jul 2023


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