FAQs for e-reporting injury data to OSHA

Date Posted: 02/17/2020
FAQs for e-reporting injury data to OSHA

March 2, 2020 is the deadline for electronically reporting your OSHA Form 300A data for calendar year 2019. Collection began on January 2, 2020. Only covered establishments must submit information, and they only submit the 300A, not the 300 Log or 301 Incident Reports.

Covered establishments include those with:

  • 250 or more employees that must keep OSHA injury and illness records, and
  • 20 to 249 employees in certain industries listed in Appendix A to Subpart E of Part 1904.

OSHA provides a secure website that offers three options for submission. First, users can manually enter data into a web form. Second, users can upload a CSV file to process multiple establishments at the same time. Last, users may transmit data electronically via an API (application programming interface). Employers in State Plan states will need to submit also, but some states use the federal portal. Check with your state office for details.

Frequently asked questions

Does coverage depend on the size of the establishment or the size of the firm?

The electronic reporting requirements are based on the size (number of employees) at the establishment, not the size of the firm or company. Injury and illness records are maintained at the establishment level, defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may have more than one establishment.

If multiple establishments do different things, should I use the industry classification of the firm or the classification of the establishment?

Use the industry the classification of the establishment, not the classification of the firm.

What if an establishment has more than one Employer Identification Number (EIN)?

The collection of 2019 data and beyond will include the each establishment’s EIN. The submission portal will accept only one EIN per establishment. If a particular establishment has more than one EIN for different lines of business, OSHA suggests using the primary EIN for the business.

We sold an establishment in 2019. Do we still need to submit data for part of the year?

No. If you no longer own the establishment, you are not required to submit injury and illness data for it. Only the current owner is required to submit data for the portion of the year that they owned the establishment.

One establishment closed permanently. Do I still have to submit data from the previous year?

No. If the establishment is permanently closed, you do not have to submit the injury and illness data. Even if the establishment closed in 2020, but before the 2020 submission deadline, you do not have to submit the 2019 data in 2020.

How Safety Management Suite Can Help

OSHA’s e-reporting can be a little tricky, even for the most experienced safety professional. If you don’t quite understand how or if the requirement applies to you, J. J. Keller® SAFETY MANAGEMENT SUITE has the solution! The Expert Help feature gives you direct access to our trusted team of in-house experts who can get you the answers you need while the Incident Center can help you create the CVS file needed for upload.

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