OSHA has published a final rule requiring certain establishments to electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA 300 Log and 301 Incident Report forms (29 CFR 1904.41). 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 rule was published July 21, 2023. Only establishments with 100 or more employees, in designated industries listed in Appendix B to Subpart E of 29 CFR Part 1904, are required to submit this detailed information. 

One way for establishments to determine whether they are required to submit these data is by using OSHA’s ITA Coverage Application. 

What does the rule require? 

• Establishments with 100 or more employees in designated high-hazard industries (listed in Appendix B to Subpart E of 29 CFR Part 1904) must electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA Form 300 Log and Form 301 Incident Report (29 CFR 1904.41). 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.
• All the establishments required to submit information from their OSHA Form 300 Log and OSHA Form 301 Incident Report to OSHA under this rule are already required to collect and retain this information and are currently required to electronically submit to OSHA information from their OSHA Form 300A Annual Summary.
• The rule did not affect the existing requirement for establishments with 20 to 249 employees in certain industries (listed in Appendix A to subpart E of 29 CFR Part 1904) to electronically submit information from their OSHA Form 300A Annual Summary to OSHA once a year. 
• The rule retains the requirement for establishments with 250+ employees in industries that must routinely keep records to electronically submit information from their OSHA Form 300A Annual Summary.
• Each establishment must provide their legal company name when submitting their data.

Why is OSHA collecting this data?

• Access to establishment-specific, case-specific injury and illness data will help the agency identify establishments with specific hazards. The collection and publication of data from Forms 300 and 301 will not only increase the amount of information available for analysis but will also result in more accurate statistics regarding work-related injuries and illnesses, including more detailed statistics on injuries and illnesses for specific occupations and industries.
• Public access to establishment-specific, case-specific injury and illness data will allow employers, employees, potential employees, employee representatives, customers, potential customers, and the general public to make more informed decisions about workplace safety and health at a given establishment.

How will electronic submission work?

The data must be electronically submitted through OSHA’s Injury Tracking Application (ITA). 

There are three ways to submit the data:

1. Webform on the ITA
2. Submission of a csv file to the ITA, or
3. Use of an application programming interface (API) feed. 

The ITA will begin accepting 2023 injury and illness data on Jan. 2, 2024. The due date to complete this submission is March 2, 2024. The submission requirement is annual, and the deadline for timely submission of the previous year’s injury and illness data will be March 2 of each year.

Monthly Toolbox Talk

According to the Center for Disease Control, the construction industry has the second highest rate of suicide in the U.S. There are approximately 123 suicides per day.

That breaks down to one death by suicide every 12 minutes. In construction, it is typical for us to discuss physical safety daily. The focus of our work plans has been on keeping ourselves and our co-workers safe from bodily harm. What we have not typically talked about is our mental health.

When you see someone physically struggling with a task do you stop them and ask them if they need help? What about our mental state and the ability to perform the task at hand? Do we conduct a Job Safety Analysis to see what hazards are floating around in our heads that day? When we see someone emotionally struggling, do we stop them and ask them if they need help?

What Makes Construction Workers Vulnerable

• Stoic, “tough guy or tough girl” culture
• Seasonal employment
• Exposure to physical strain
• Capability for fearlessness
• Fragmented community or isolation
• Industry with the highest rate of prescription opioids
• Culture of substance abuse
• Access to lethal weapons
• High pressure with risk of failure

Know the signs

• Increased tardiness and absenteeism
• Decreased Productivity
• Decreased self-confidence
• Isolation from peers
• Agitation and increased conflict among co-workers
• Increased feelings of being overwhelmed

What do we do?

If you suspect someone is at risk for suicide, it is important to ask directly about suicidal thoughts. Do not avoid using the work “suicide.” It is important to ask the question without expressing negative judgment. The question must be direct and to the point. If you appear confident in the face of a suicide crisis, this can be reassuing for the suicidal person.

For example, you could ask:

• Are you having suicidal thoughts?
• Are you thinking about killing yourself?
• Are you OK?

Information provided by the Occupational Safety and Health Administration (OSHA). Prepared and edited by Michael Ballantine, Occupational Safety Consultants (www.workriskfree.com)