Pursuant to the Occupational Safety and Health Administration’s (OSHA) electronic reporting regulation, covered employers must submit their OSHA injury and illness records (OSHA Forms 300, 300A, and 301) using OSHA’s electronic Injury Tracking Application by March 2, 2025.
With the reporting deadline quickly approaching, employers should determine whether they must submit an electronic report, and if so, how to navigate the ITA system.
What is OSHA’s Injury Tracking Application?
Launched in January 2024, OSHA’s Injury Tracking Application (ITA) is on online portal that allows covered employers to submit their OSHA injury and illness records (OSHA Forms 300, 300A, and 301) electronically each year.
New ITA users will be required to create an account and complete an establishment profile before submitting the required records. Employers who reported via the ITA last year may use their existing account and establishment profile. However, returning employers should be sure to update their establishment profile to reflect any relevant changes over the reporting year. OSHA’s ITA User Guide and FAQ page provide helpful information about creating and maintaining an ITA account as well as navigating the ITA portal.
Must My Establishment Submit an Electronic Report?
Only certain establishments are required to submit electronic reports via the ITA each year. Reporting requirements differ depending on employer size and industry, as detailed below:
- You must submit OSHA Form 300A via the ITA if:
- Your establishment has 250 or more employees and is in an industry not listed in Appendix A to Subpart B of OSHA’s recordkeeping regulation; OR
- Your establishment has 20–249 employees and is in an industry listed in Appendix A to Subpart E of OSHA’s recordkeeping regulation.
- You must submit OSHA Forms 300A, 300, and 301 via the ITA if:
- Your establishment has 100 or more employees and is in an industry listed in Appendix B to Subpart E of OSHA’s recordkeeping regulation.
OSHA does not notify employers as to whether they must electronically submit their injury and illness records using the ITA. To ensure OSHA compliance, employers must independently determine whether they are subject to the electronic reporting requirements. Luckily, OSHA recently created a helpful tool to assist employers in determining their electronic reporting requirements.
If My Establishment Is Exempt From Electronic Reporting, Do I Still Have to Complete OSHA Forms 300, 300A, and 301?
Even if you determine that your establishment is not required to submit electronic reports via the ITA, you must still keep a record of serious work-related injuries and illnesses using OSHA Forms 300, 300A, and 301 (or equivalent forms), unless your establishment is considered exempt. Employers who are uncertain about whether they must submit an electronic report this year should contact counsel for advice and clarification.
