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January 2024 - OSHA Recordkeeping Time - Updated links and information

New Requirements for 2024

Establishments with 100 or more employees in designated high hazard industries listed in Appendix B to Subpart E of 29 CFR 1904 must electronically submit to OSHA detailed information about each recordable injury and illness entered on thier previous calendar year's OSHA form 300 and Form 301.

You can check to see if this new requirement applies to you at

This includes the date, physical location and severity of the injury or illness; details about the worker who was injured; and details about how the injury or illness occurred.

The new data will help OSHA and third parties such as prospective employees and research groups to more clearly define hazards and controls that can improve workplace safety. There will be controls on the dat to prevent any reports from identifying a specific individual.

Existing Requirements

OSHA requires that employers with 10 or more employee maintain records of serious work-related injuries and illnesses. Some low hazard employers are exempted from this regulation. Click for a list of exempt employers. Minor injuries requiring first aid only do not need to be recorded.

Reporting Serious Injuries – All employers, regardless of size or industry must report any worker fatality within 8 hours and any amputation, loss of an eye or hospitalization of a worker within 24 hours. These events can be reported online or by phone.

Maintaining and Posting Records – OSHA logs and supporting records must be maintained at the worksite for a period of five years. Each February through April the employer must post a summary of injuries and illnesses recorded during the prior year. This form is part of the OSHA 300 form set. Fillable forms are online at the OSHA web site

Electronic Submission of OSHA 300A Data – Any employer with 250 or more employees must submit their OSHA 300A summary data to OSHA electronically. There is a list of establishments that must also report their 300A summary data to OSHA. These establishments will report if they have 20 or more employees but less than 250 employees.

The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you can provide the Agency your OSHA Form 300A information. There are new sign-in procedures since October 2022. The above link will help you navigate these changes. The date by which the above noted employers are required to submit to OSHA the information from their completed Form 300A is March 2nd of the year after the calendar year covered by the form.

Incident Rate Calculations – Your OSHA 300 data has some of the values needed for calculating your total incident rate and your days away, restricted or transferred (DART) rate. You can download fillable PDF forms from OSHA. A detailed calculator that allows you to benchmark your business against both state specific and national trends can be found at the Bureau of Labor Statistics calculator.

Incident and DART rates are often used in qualifying contractors and suppliers for bids. Making sure your data is sound for these calculations can be an important step in qualifying for some business opportunities.

The incident rates may be used by insurers when evaluating workers compensation and general liability exposures. Companies that have a higher than average injury rate or a higher than average rate of serious injuries as indicated by the DART rate may have less attractive terms and conditions for insurance coverage.

First Aid Only Cases – OSHA requires that only serious injuries or illnesses be recorded. There are criteria to define a first aid event. You should be familiar with these requirements and use them in your recordkeeping process. It is not in your interest to have incidents that are not recordable on your OSHA log. Click here for the OSHA first aid definition

The Driehaus Difference

Insurance without risk management is only a partial solution. We understand the insurance marketplace as well as the OSHA rules, recordkeeping and how this data is used in business and insurance.

If you need help, we have the expertise and resources to help you manage this important information. Visit our website at or call our office 513-977-6860 to contact us. We look forward to helping with your risk management program.


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