OSHA Expands Electronic Injury and Illness Reporting Requirements for 2024

What Changed

The Occupational Safety and Health Administration (OSHA) finalized a rule effective January 1, 2024, that significantly expands electronic injury and illness reporting requirements. There are two key compliance obligations for early 2024:

Annual Form 300A Posting (All Covered Employers)

The OSHA Form 300A — Summary of Work-Related Injuries and Illnesses must be posted in a visible workplace location from February 1 through April 30, 2024, summarizing injuries and illnesses for calendar year 2023.

Expanded Electronic Submission (New for 2024)

Under the new rule, establishments with 100 or more employees in designated high-hazard industries (identified by NAICS codes in Appendix B to Subpart E of 29 CFR Part 1904) must now electronically submit:

• Form 300 — Log of Work-Related Injuries and Illnesses

• Form 301 — Injury and Illness Incident Report

• Form 300A — Summary (previously the only required electronic submission)

All electronic submissions must be made through OSHA's Injury Tracking Application (ITA) by March 2, 2024, for calendar year 2023 data. Submissions must now include the establishment's legal company name.

The existing requirement for establishments with 250+ employees to submit Form 300A electronically remains in effect. Establishments with 20–249 employees in certain high-hazard industries must also continue submitting Form 300A.

Who Is Affected

• Form 300A posting: All employers required to keep OSHA injury and illness records (generally, employers with 11+ employees not in exempt low-hazard industries)

• Expanded electronic reporting (Forms 300, 301, 300A): Establishments with 100+ employees in high-hazard industries listed in Appendix B

• Existing electronic reporting (Form 300A only): Establishments with 250+ employees in industries required to keep records, and establishments with 20–249 employees in designated high-hazard industries

Where It Applies

Federal OSHA requirements apply nationwide. Employers in states with OSHA-approved State Plans (such as California, Michigan, and Washington) should confirm whether their state has adopted equivalent requirements, as State Plan states must adopt standards at least as effective as federal OSHA.

When It Takes Effect

• February 1, 2024: Begin posting Form 300A summary at worksites

• March 2, 2024: Deadline for electronic submission of Forms 300, 301, and 300A through OSHA's ITA

• April 30, 2024: End of Form 300A posting period

Why It Matters

OSHA intends to make the electronically submitted data—including company names—available to the public in a searchable online database. This means your injury and illness records will be more visible than ever, creating both compliance risk and reputational considerations. Failure to submit required forms can result in citations and penalties of up to $16,131 per violation for non-willful violations and up to $161,323 per violation for willful violations under OSHA's current penalty structure.

The Humareso Take

This is a significant expansion that catches a lot of mid-size employers off guard. If you have 100+ employees and you're in a high-hazard industry, you went from submitting just the 300A summary to submitting detailed incident-level data. The public database component adds another layer of urgency—your data will be searchable. We recommend getting your 2023 records in order now and submitting well before the March 2 deadline rather than scrambling at the last minute.

Recommended Action Steps

1. Post the OSHA Form 300A summary in a visible workplace location by February 1, 2024, and maintain it through April 30, 2024.

2. Determine your electronic reporting obligations by checking whether your establishment meets the 100+ employee threshold and whether your NAICS code is listed in Appendix B.

3. Compile and review 2023 injury and illness records (Forms 300, 301, and 300A) for accuracy and completeness.

4. Submit required forms electronically through OSHA's Injury Tracking Application (ITA) by March 2, 2024, including your establishment's legal company name.

5. Review your OSHA recordkeeping practices to ensure ongoing compliance with documentation and retention requirements.

6. Contact your Humareso representative if you need help determining your reporting obligations or preparing your electronic submission.