New OSHA Rule Requires More Injury and Illness Reporting for High-Hazard Industry Employers with 100+ Employees

OSHA believes that this rule will reduce occupational injuries and illnesses.

Effective on January 1, 2024, OSHA is amending its occupational injury and illness recordkeeping regulation. It will now require certain high-hazard employers to electronically submit injury and illness information to OSHA, which they are already required to keep in their records according to the regulation.

Under the new rule, there will be four major changes:

1. Require establishments with 100 or more employees in certain high-hazard industries to electronically submit information from their OSHA Forms 300, 301 and 300A to OSHA once a year.
2. Update the classification system used to determine the list of industries covered in the rule.
3. Remove the current requirement for establishments with 250 or more employees, NOT in a designated industry, to electronically submit information from their Form 300A to OSHA annually.
4. Require employers to include their company name when making electronic submissions to OSHA.

New high-risk industries added to appendix B include:

• Logging
• Hunting and Trapping
• Other Furniture Related Product Manufacturing
• Miscellaneous Durable Goods Merchant Wholesalers
• Taxi and Limousine Service
• Other Support Activities for Transportation

For the full list of industries on the list, see the end of the article below.

It is important to note that OSHA will NOT:

• collect employee names or addresses,
• names of health care professionals, or
• names and addresses of facilities where treatment was provided if treatment was provided away from the worksite from the Forms 300 and 301

OSHA estimates that this rule will have economic costs of $7.7 million per year, including $7.1 million per year to the private sector, with the average yearly cost being $136 for affected establishments with 100 or more employees, annualized over 10 years with a discount rate of seven percent. The agency believes that the annual benefits, while unquantified, significantly exceed the annual costs.

Why the new changes?

First, OSHA will use this data to intervene through strategic outreach and enforcement to reduce worker injuries and illnesses in high-hazard industries.

For example, it can help OSHA’s efforts to address indoor and outdoor heat-related hazards. As climate change has accelerated, every year heat hazards are increasing with more heat-related sicknesses and deaths among workers. Currently, OSHA most often learns of these hazards after an employer reports a worker hospitalization or death.

This move restores the rights for workers at Amazon and other companies with high injury rates to access essential information. It gives these workers a chance to learn more about the dangers in their workplaces and demand that employers fix them.

So, expect more targeted enforcement campaigns in the following years.

For employers, the collected data would provide direct access to detailed injury and illness information to compare their injury and illness records and experience with others in the same industry. Benchmarking safety performance to more comparable establishments and employers instead of large, anonymous aggregates would provide more accurate metrics for guiding and motivating them to improve on safety programs.

Lastly, workplace safety consultants and other workplace safety professionals will be able to use the collected data to improve workplace safety and health.

Have an illness and want to avoid busy Doctor’s offices or medical facilities?

Start your customized health plan to meet your business needs and keep your employees healthy and safe.

Our Occupational Medicine Team will develop a custom plan for your company. You may need a combination of services related to:

• Workers’ Compensation
• Physicals and Biometric Screenings
• Respiratory Fit Testing
• Nurse Triage
• and more

We understand the impact that lost time, limited duty, and medical costs have on the company and the employee. So, work with an occupational medicine provider that can be staffed on-site or have a mobile health clinic come to reduce employee downtime away from the office.

We also have a strong understanding of the OSHA recordkeeping rule and how certain medical diagnosis and treatments impact your OSHA 300 log.

Contact our medical team to develop your custom plan at 800.551.9816 or info@cnsoccmed.com.

---