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