As previously reported, OSHA has expanded its requirements to electronically submit employee injury data through its Final Rule on Improving Tracking of Workplace Injuries and Illnesses. Nearly all long term care (LTC) providers are already required to maintain OSHA 300 Logs, Form 301, and Form 300A, but for the last several years, have only submitted the 300A summary to OSHA—typically by March 2nd of the following year. The updated regulation requires electronic submission of OSHA 300 logs and Form 301 (incident reports), in addition to the 300A summaries that are already submitted electronically.
Complete instructions for OSHA Form 300-Log of Work-Related Injuries and Illnesses, Form 300A-Summary of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report includes all the forms, step by step guidance, and frequently asked questions. OSHA will publish some of the data collected on its website and believes that providing public access to the data will ultimately reduce occupational injuries and illnesses.
It's essential to understand that while this updated regulation went into effect on January 1, 2024, it applies to the 2023 data you'll be submitting by March 2, 2024. Meaning, the current year (2023) 300 logs, Form 301, and 300A summaries must comply with this new requirement and be submitted before March 2, 2024. Please note that contracted personnel such as temporary nursing services are included in reporting requirements, and employers should clarify how OSHA record keeping and reporting is being managed in their written agreements with subcontractors.
Please visit OSHA and its injury and illness recordkeeping and reporting requirements for more information.