In 2017, the Occupational Safety and Health Administration's (OSHA) Recordkeeping regulation ( 29 CFR 1904) went into effect, which began requiring many employers to submit certain electronic data in regards to employee injuries and illnesses for the first time.  Though there are still some states who have not yet adopted this requirement into their OSHA-Approved State Plan, making establishments within them exempt from this requirement for now, it is expected that this adoption will occur.  The intent of this rule is to phase in the submission of such data over the first two years of applicability in order to not overwhelm reporters.  Through the publication of this data on, the agency hopes to encourage employers to reduce their numbers of employee injuries and illnesses via awareness of performance in relation to industry peers as well as the promotion of proactive data analytics.

As part of the aforementioned phase-in process, OSHA set a deadline for July 1, 2017 for any establishment with 20 or more employees to electronically submit Form 300A regarding workplace injuries and illnesses in 2016.  Within such businesses, responsible personnel must now create login accounts for OSHA's Injury Tracking Application (ITA), enter information regarding all applicable sites, and then facilitate data entry for each site's Form 300A data on an annual basis.

For many firms, the previous manual process of filling out an annual OSHA Form 300A and posting it in each of their offices was already a time and resource intensive task.  Now, with the additional requirement of electronic data submissions to OSHA being phased in, employers who do not have an EHS technology solution deployed are finding that handling both the old and new requirements is quite burdensome.  First, injury and illness incidents data that is not contained in a centralized technology solution is often scattered and must be manually gathered and verified.  Second, such data must often be converted to the proper electronic format before submission to OSHA is possible.

Many businesses and industries utilize EHS technology solutions to assist with incidents data management, and in turn these companies maintain advantages that decentralized manual data processes do not entail.  These include:

  • Improved Efficiency for Incident Data Flow Processes 
  • Improved Accountability for Incident Investigation and Prevention
  • Task Tracking and Notification Capability for Corrective Actions and Proactive Measures
  • Increase in Collaboration and Sharing of Lessons Learned
  • Automated Creation of Important OSHA Forms Such as 300, 300A, and 301
  • Additional EHS Data Analytics Capabilities with Automated Reporting Capabilities

However, with the new electronic data submission requirements from OSHA, the most significant advantage that many EHS technologies promote is the ability to perform annual electronic OSHA submissions within the solution through an officially endorsed OSHA ITA application program interface that has been made available to developers.  The magnitude of this advantage is highest when a particular business must submit OSHA data for multiple sites because this eliminates the need to perform multiple upload processes on ITA.

On July 1, 2018, in addition to the requirement for electronically submitting Form 300A, establishments with 250 employees or more must also submit Form 300 and Form 301 electronically.  In 2019, the standard submission timing will go into effect whereby employers must make these electronic submissions at the beginning of March.  This effectively means that applicable establishments will be required to report twice in less than a year, and further incentivizes companies to deploy a centralized EHS technology solution for incidents data management.

T3, a division of Trinity Consultants specializing in EHS technology solutions with personnel nationwide, has over 20 years of experience assisting businesses with all phases of EHS technology implementations.  Depending on the existing EHS technology infrastructure at a business, this may include any combination of the needs assessment and solution selection process, the deployment of solutions with one of our trusted technology partners, the creation of low-cost and custom solutions utilizing Microsoft software, or improving the effectiveness of a previously implemented solution.

If you need assistance in determining how EHS technology solutions can streamline this new reporting process, contact T3 by email or by phone at (972) 661-8121.