Safety Tidbit 3.06 - Establishment Size and Electronic Submission of Injuries

Safety Tidbit 3.06 – Establishment Size and Electronic Submission of Injuries and Size

Reference(s): 29 CFR 1904.41

OSHA has launched its electronic injury and illness submission website (https://www.osha.gov/injuryreporting/). Therefore, before December 31, 2017 all establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. Those covered establishments with 250 or more employees must electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report). Covered establishments with 20-249 employees must electronically submit information from OSHA Form 300A.

The question I seem to be hearing most is about the size of the establishment – “Is the 20 or 250 based on the entire company or the facility?” OSHA has defined the term establishment back in 1904.2 and 1904.30. In short, each business site is an establishment. Therefore, each establishment (with 20 or more employees) gets an entry into OSHA’s Injury Tracking Application. If you have multiple establishments one person can input data for the whole company just like you need to fill out the OSHA 300 and 300A forms as specified in 1904.30.

Now to add to the step process I introduced in my very first Safety Tidbit more than two years ago:

1. Is this a permanent establishment (one year or longer)? No – OSHA 300 not required. Keep injury/illness information with corporate records [1904.30(a)]. Answer = Yes? Continue to Question 2.

2. Is the primary industry at the permanent establishment listed as low hazard rating?  Yes – OSHA 300 not required [1904.2(a)(1)]. Answer = No Continue to Question 3.

3. Does the permanent establishment or the entire company have more than ten employees? No – OSHA 300 not required [1904.1(b)(1)] Answer = Yes Then an OSHA 300 must be kept for the permanent establishment.

4. Does the permanent establishment have 20 or more employees? No – Online reporting not required [1904.41(a)(2)]. Answer = Yes Online recordkeeping required to OSHA’s website (https://www.osha.gov/injuryreporting/) and launch ITA.

5. Does the permanent establishment have 250 or more employees? No – No further recordkeeping required. Answer = Yes OSHA 300A form information must be entered by December 31, 2017 and all OSHA 300, 300A, and 301 form information must be entered into OSHA’s ITL by July 1, 2018.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.