News & Information Blog

I am still getting questions about OSHA’s Information Tracking Application, ITA, Electronic Reporting Requirements. 

Specifically:

1. Who has to report?
2. What do you have to report?
3. How do you report?
4. What if I missed the March 2^nd deadline?

Who has to report electronically?

In order to answer this question you must understand the difference between a Firm and an Establishment.  Think of your local school district.  The District is the firm and each School is an establishment.

A Firm can have one establishment that conducts business under a North American Industry Classification System, NAICS, code that is required to report electronically and another establishment with a NAICS code that does not fall under this requirement. 

• If you have an establishment with a NAICS code in the list in 1904 Subpart B App A

AND

• The establishment has 250 or more employees

You have to report electronically.

However, if you have a NAICS code on this list you must report electronically if you have 20 to 249 employees.

What do you have to report?

OSHA published a final rule on January 25^th 2019 that only the 300A, the summary of the data in the 300 log, must be submitted electronically.

If your business has closed you don’t have to report.

If you have no recordables in the last year, Great Job, but you still have to report.

How do you report?

Electronic reporting requirements are at the establishment level.  Submission of the data can be:

• Under the Firm’s account,
• Under the establishment’s account
• By a third party,
  • NOTE: the Firm is responsible for inaccurate or incomplete data

Be sure you don’t combine the data from two or more establishments, each must submit the summary data for their own establishment.

If your OSHA data is on an excel spreadsheet from the OSHA website you can’t save it as a .csv file and upload it because it would be in the wrong format.  The correct template can be found at this link.  However, OSHA states it is much easier to use the webform provided on the reporting site.

What if I missed the March 2^nd deadline?

I asked an OSHA Compliance Officer what to do if a business missed the deadline and he said to try to submit the data.  It may or may not be still accepted.