The Occupational Safety and Health Administration (OSHA) recently amended its occupational injury and illness recordkeeping regulations, requiring certain employers in high-hazard industries (which includes breweries) to now electronically submit the data that they are already required to keep. With more data, OSHA will be better equipped to protect employees through outreach activities and enforcement efforts.
Who Does This Affect?
Establishments (single physical locations) that meet both qualifications below:
- Have 100 or more employees based on the total number of employees at an establishment during the previous calendar year, including all full-time, part-time, temporary, and seasonal employees, not counting unpaid volunteers. For businesses that are sole proprietorships or partnerships, the owners and partners would not be counted.
- Are in states under Federal OSHA jurisdiction. If your establishment is in a State Plan State, please contact your Occupational Safety and Health (OSH) plan for guidance. Find out more at OSHA’s State Plans page.
Note that establishments with 20 to 249 employees in certain industries and all establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation will also continue to be required to electronically submit information from their OSHA Form 300A to OSHA once a year.
To easily determine whether you must electronically submit your data, visit OSHA’s Injury Tracking Application (ITA) Coverage Application page.
What Needs To Be Submitted?
Establishments’ injury and illness data from all the forms below:
- OSHA Form 300: Log of Work-Related Injuries and Illnesses
- OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
- OSHA Form 301: Injury and Illness Incident Report
Reference the Brewers Association’s (BA) resource on Making Sense of OSHA’s 300, 300A, and 301 Forms for more information.
When Does This Need To Be Done?
The new rule is now effective as of January 1, 2024. The previous year’s data needs to be submitted once a year. Data submission for 2023 is currently being accepted. Every year, March 2 will be the deadline to submit the previous year’s data.
- February 1, 2024: Deadline to visibly post Form 300A data in the workplace
- March 2, 2024: Submission deadline for 2023 data
Where Can I Do This?
Submit data through OSHA’s Injury Tracking Application on its secure website. Find out how you can submit data (manually enter, upload a file, or transmit electronically) and much more on OSHA’s Injury Tracking Application (ITA) Information page.
Establishments are required to include their company name in data submissions. OSHA intends to post some of the accumulated data to a public website after removing information that could identify individuals, such as their names and contact information.
OSHA does not collect employee names or addresses, names of health care professionals, or names and addresses of facilities where treatment was provided if treatment was provided away from the worksite.
Check out the Frequently Asked Questions (FAQ) page for the Injury Tracking Application to get all questions answered.