OSHA Injury/Illness Records Rules Open to Comment

The OSHA requirements for employers to record and submit workplace injuries and illnesses data are up for a scheduled three-year review by the Office of Management and Budget (OMB). All comments submitted on or before March 31, 2025 will be considered. 

Under 29 CFR Part 1904, OSHA requires covered employers to maintain a record of workplace injuries and illnesses, often called an OSHA 300 Log. In addition, employers must make timely reports of injury and illness events that result in fatality, amputation, eye loss, or hospitalization. For certain large employers and employers in high-risk industries, annual submission of injury and illness data is mandatory. Covered employers must submit information electronically through OSHA’s online Injury Tracking Application (ITA) by March 2 each year. 

The public comment period for OMB's review was announced in the Federal Register last week. Public comments can be submitted using that link as well.

OMB is requesting comments on: 

1. Whether the collection of information is necessary for the proper performance of the functions of the Department, including whether the information will have practical utility;
2. The accuracy of the agency's estimates of the burden and cost of the collection of information, including the validity of the methodology and assumptions used;
3. Ways to enhance the quality, utility and clarity of the information collection; and
4. Ways to minimize the burden of the collection of information on those who are to respond, including the use of automated collection techniques or other forms of information technology.

2024 Change to Injury and Illness Submissions 

OSHA revised the requirements for annual injury and illness submissions, effective January 1, 2024. The regulations in 29 CFR 1904 now require certain workplaces with 100 or more employees to submit information from OSHA Forms 300A, 300, and 301. The expanded submission requirement applies to employers in very high risk industries, a list of which is now found in Appendix B to 29 CFR Part 1904, Subpart E. 

Cheat Sheet: OSHA Injury and Illness Records and Reporting

What is an Information Collection Request or ICR?

In general, the Paperwork Reduction Act prohibits Federal agencies from requiring any person to submit information or keep records unless the request (or requirement) is approved by the Office of Management and Budget. Once approved, each ICR is assigned an “OMB Control Number.”  

ICRs must be reviewed, opened to public comment, and re-approved by OMB every three years. While undergoing review, ICRs remain in effect on an month-to-month basis. 

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