The New Standard
On January 1, 2024, a major addition to Subpart E of 29 CFR 1904, the Recordkeeping Standard went into effect. This rule expands the information that must be submitted annually to OSHA electronically for industries specifically listed in Appendix B of Subpart E of the standard. This applies to employers that had more than 100 employees at any time during the previous calendar year.
Who is Affected
Since 2017, employers with 20 to 249 employees have been required to submit their Form 300A Summary of Work-Related Injuries and Illnesses if they are included in Appendix A of Subpart E. This has not changed. However, all employers with more than 250 employees at any time during the previous calendar year and who are not partially exempt (Appendix A to Subpart B) from the recordkeeping requirements are required to also submit Form 300A to OSHA.
The new requirements provide that certain employers that are considered in a high-hazard industry must also submit Form 300 Log of Work-Related Injuries and Illnesses and Form 301-Injury and Illness Accident Report. Whether an employer is included in the list of high-hazard industries is based on the Company’s classification in the North American Industry Classification System (NAICS). In this system, businesses are classified by type, and each type is given a number. Before submitting the data, check the list to determine if your classification number is on the list. Not all classification numbers in a particular industry are included in the high-hazard category.
Some examples of high-hazard categories include the following:
- Construction – Only NAICS Code 2381 Foundation, Structure, and Building Exterior Contactors are included.
- Utilities – Only NAICS Code 2213 Water, Sewage, and Other Systems are included.
- Foundries NAICS Code 3315
- Waste Management and Remediation – Only NAICS 5621 Waste Collection and 5622 Waste Treatment and Disposal.
Many additional categories are included, so it is important to confirm your company’s classification.
Form 300 Submission Guidelines
The employees’ names should be omitted when submitting the 300 log.
The following information should be omitted when submitting Form 301:
- the employee’s name and address
- the name of the physician or other health care professional
- the facility name and address of the treating facility, if away from the worksite
All other information on the forms is required.
When is the Submission Deadline
For 2023 records, all information must be electronically submitted by March 2, 2024, and annually thereafter.
How to Get More Information
Since 1995, Circle Safety’s team of highly trained safety professionals has assisted our clients with OSHA Recordkeeping. If you have any questions about the new OSHA Recordkeeping Standard or need assistance in ensuring that your company complies with the new requirements, please contact our Managing Director, Anna Jolly, at 804-355-7255.
