The OSHA Rule Change — Are You Ready?

If you work in a high-hazard industry, you are familiar with OSHA standards, reporting requirements, and OSHA forms. However, things are changing effective January 1, 2024. Are you ready? A new rule is going into effect on January 1, 2024, requiring certain employers to submit their OSHA forms electronically to OSHA by March 2 of each year. These reports will be for the previous year. So, while you have plenty of time between now and March 2, getting your ducks in a row is essential.

The new requirements state, “OSHA is amending its regulation to require establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year. OSHA will not collect employee names or addresses, names of healthcare professionals, or names and addresses of facilities where treatment was provided if treatment was provided away from the work site from the Forms 300 and 301. Establishments with 20 to 249 employees in certain industries will continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year. All establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation will also continue to be required to electronically submit information from their Form 300A to OSHA on an annual basis.”


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While it’s still unclear which industries need to file as the agency is updating their list of partially exempt organizations and requirements for reporting, you can assume that if you’re currently required to track, you will have to report by March 2. However, you can complete the ITA Coverage Application to see if you are required to submit your data. In addition, OSHA states that establishments that meet the following requirements do not have to submit their data electronically:

  • The establishment’s peak employment during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
  • The establishment’s industry is on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the size of the establishment.
  • The establishment had a peak employment between 20 and 249 employees during the previous calendar year, AND the establishment’s industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.


While January seems far away, you can take steps now to prepare. First, complete your OSHA Forms 300, 300A, and 301 as needed. You can find these forms on the OSHA site here: 

Ensure that you have them correctly filled out. Then, take time to understand the OSHA requirements and what your responsibilities are. OSHA has created a web page with FAQs about the ruling and information on how to submit your data.

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OSHA will be accepting data starting on January 2, 2024, and all data must be submitted by March 2. This can be done by uploading a CSV, or they also allow an API, which is an application programming interface. Talk with your IT team or HRIS/Safety systems administrator to see if an API would work for your organization.

This change aims to create more transparency on workplace hazards at the industry level to help organizations make more sound decisions and processes on health and safety in the workplace. We recommend contacting OSHA or your legal team if you have questions about this ruling.