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The Occupational Safety and Health Administration (OSHA) set forth new recordkeeping requirements in its July 2023 final rule. The rule, among other things, mandates publication of 2023 workplace injury data that certain employers must submit to OSHA.
This requirement applies to employers that have more than 100 employees in various “high hazard” industries. This includes agriculture, manufacturing, grocers, construction, transportation, warehousing and storage, and retail. The size criterion of 100 or more employees is determined by the number of employees at an “establishment” during the previous calendar year. An establishment is defined as “a single physical location where business is conducted or where services or industrial operations are performed.”
The regulation will require employers to electronically submit information from their OSHA Forms 300 and 301 to OSHA once per year. As a reminder, the Form 300 refers to the Log of Work-Related Injuries and Illnesses, while the Form 301 refers to the Injury and Illness Incident Report.
OSHA has created a secure website for the electronic reporting system, the Injury Tracking Application (ITA).
Notably, OSHA intends to publish data from employers’ submissions on a public website after removing any information that could identify individual employees. However, the agency has yet to specify precisely what information it plans to publish.
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