Enforcement and Inspection

You Have Extra Time to Submit 300A Data … But Don’t Wait Too Long

If you haven’t submitted your completed 2016 300A annual summary data to OSHA yet, don’t worry. The Agency said that it will not take enforcement action against employers who submit their data after the December 15, 2017, but before the December 31, 2017, final entry date. Be sure to submit the required information because the portal will no longer accept the 2016 300A annual summary data starting January 1, 2018.

electronic reporting recordkeeping filing

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Under the rule, private sector establishments that have 250 or more employees and establishments with more than 20 but fewer than 250 employees in high-risk industries listed in appendix A of the rule were required to submit their completed 2016 300A data via the Injury Tracking Application (ITA) – Electronic Submission of Injury and Illness Records to OSHA by December 15, 2017. The Agency will now allow you to submit your data by midnight December 31, which is the deadline to edit submitted data for 2016 incidents.

The data submission process involves four steps:

  1. Create an establishment;
  2. Add 300A summary data;
  3. Submit data to OSHA; and
  4. Review the confirmation e-mail from the Agency.

The secure website offers you three options for submitting your data. One option allows you to manually enter data into an online form. Another option gives you the ability to upload a CSV file (like an excel spreadsheet) to process a single or multiple establishments at the same time. For the third option, if you use an automated recordkeeping system, you can submit your data electronically using an application programming interface—or API.

But let’s not forget public sector establishments. All public sector employers (establishments with 1 or more employees) must also use OSHA’s secure website to submit their 300A data.

Although there is uncertainty about the future of the rule, if you are an affected establishment that is required to submit records, familiarize yourself with the ITA site and submit your 300A data by December 31, 2017. The portal will not accept 2016 data beginning January 1, 2018.