In July 2023, the U.S. Department of Labor introduced a significant update to injury and illness reporting requirements for numerous construction companies. This new rule, effective since January 1, 2024, mandates that companies in certain “high hazard” industries, with 100 or more employees, electronically submit specific documents to OSHA annually. These documents include Form 300A (Summary of Work-Related Injuries and Illness), Form 300 (Log of Work-Related Injuries and Illnesses), and Form 301 (Injury and Illness Incident Report to OSHA).
Affected contractors and subcontractors, particularly those under NAICS Code 2381 – Foundation, Structure, and Building Exterior Contractors, are required to adhere to these new reporting guidelines. A comprehensive list of NAICS codes subject to the reporting requirements can be found in Appendix B to Subpart E of 29 CFR Part 1904. R. Construction companies with 20 or more employees must annually electronically submit their Form 300A Summary of Work-Related Injuries and Illness to OSHA. The deadline for reporting is March 2, 2024, covering the forms for the 2023 reporting period.
To determine if your company needs to comply with the new reporting requirements, OSHA has developed the “Injury Tracking Application (ITA) Coverage Application” website. This tool allows you to input company-specific information to determine which reporting obligations apply to your organization. If your company falls within the reporting requirements, the OSHA Injury Tracking Application can be used to submit the records online.
It is crucial to note that the information submitted to OSHA will be made publicly accessible. Therefore, exercise caution to avoid disclosing personally identifiable information in the Form 300 Log and Form 301 Incident Reports. This includes details such as employee names, social security numbers, contact information, healthcare provider details, and family member information.
While OSHA plans to employ scrubbing technology to remove certain personally identifiable information before public access, it remains essential for companies to safeguard their employees’ privacy rights. According to OSHA guidance, companies should only include the employee’s date of birth (automatically converted to age before publication), job title, date hired, and gender. Additionally, if the incident or injury qualifies as a “privacy concern case,” companies may redact additional employee information before submission.
As the March 2 deadline approaches, it is imperative for affected construction companies to ensure timely and accurate submission of the required OSHA safety records while prioritizing the protection of employee privacy. Stay compliant and contribute to a safer and more transparent work environment.
Ensure compliance and peace of mind with IFO Group’s Retainer Services, offering dedicated support for the meticulous review and maintenance of your OSHA 300 log. With our retainer services, you gain unlimited access to our knowledgeable consultants via phone or email, allowing you to seek technical advice whenever you need it. Additionally, our retainer services provide you with a dedicated consultant who can efficiently handle tasks both onsite and remotely. Whether you require assistance in understanding the intricacies of OSHA reporting, need guidance on the submission process, or want a thorough review of your safety records, IFO Group’s Retainer Services are designed to provide comprehensive support tailored to your unique needs. Contact us at info@ifogroup.com or at 832-403-2135 to learn how we can help your organization adhere to OSHA requirements and promote a workplace culture of safety and compliance.
