OSHA Proposes New Record-keeping Requirements

May 17, 2022
Inside HR
Safety & OSHA
Read time: 2 mins

The Occupational Safety and Health Administration (OSHA) has proposed a change to the record-keeping and reporting requirements for certain high-risk industries. Currently, employers with 250 employees or more, and those classified in certain industries by the North American Industry Classification System (NAICS) with 20 to 249 employees, are required to electronically submit Forms 300, 301, and 300A to OSHA on an annual basis. The agency identifies and responds to the reports and makes aspects of them public, in an effort to identify emerging hazards in workplaces where workers are at high risk of accident, injury, or work-related illness.

Included in the proposed changes is the recommendation to move the employee count for electronic reporting from 250 or more employees to 100 or more employees. The agency has also proposed:

  • Reviewing and updating the classification system for industries covered by the electronic submission requirement.
  • Including each Form 301 with the annual submission, which includes details of individual incidents, along with the already required aggregate reporting Form 300A.
  • Requiring companies to include the organization’s name on the forms, but removing information that reasonably identifies individuals, such as name and contact information.
  • Removing the annual electronic submission requirement of Form 300A, for companies with 250 or more employees, who are not in a designated industry.

OSHA has stated the goal of the newly recommended reporting requirements is to aid in empowering employees by creating transparency in the workplace. There is concern from business groups that the change in reporting may contribute to the recent uptick in organized labor efforts. At this stage, the announcement is only to suggest the changes, which have not been finalized. Comments on the proposed changes are being accepted through May 31.