OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements
OSHA has issued a final rule changing some of the requirements for electronic injury and illness reporting, adding some new companies and increasing som...
OSHA has issued a final rule changing some of the requirements for electronic injury and illness reporting.
⚡ TL;DR: OSHA’s updated recordkeeping rule now requires companies with 100+ employees in high-hazard industries (Appendix B) to submit not just the 300A summary but also the detailed 300 and 301 forms. The rule also requires company legal names on all submissions. Several NAICS codes moved from lower-risk to high-risk classification, including Logging, Hunting and Trapping, Furniture Manufacturing, Taxi and Limousine Services, and Transportation Support Activities. These changes increase OSHA’s visibility into specific injuries and illnesses, not just summary data.
What’s New
A new Appendix B has been created for companies with 100 or more employees. In addition to submitting the 300A, the 100+ employee companies who fall under Appendix B will also need to submit their 300 and 301 forms. The rules have not changed for all companies with 250 or more employees. Another change includes making inclusion of your company’s legal name required.
⚠️ The Pain Frame: Submitting the detailed 300 and 301 forms (not just the 300A summary) means OSHA gets line-by-line visibility into every recordable injury — date, classification, body part affected, duration of lost worktime. This data flows into OSHA’s enforcement targeting system. Facilities with high injury rates in specific hazard areas become high-priority inspection candidates. A facility reporting 15 recordable injuries in a year that includes 5 hand injuries from machinery gets OSHA’s attention for machine guarding enforcement. The detailed forms also reveal patterns — if you’re reporting the same injury type repeatedly, OSHA can cite systemic control failures rather than isolated incidents. Companies failing to properly classify injuries in submitted data face discovery during subsequent inspections when OSHA cross-references your submitted forms against worker interviews.
Some NAICS codes were moved due to increased fatalities or increases in DART rates, including Logging, Hunting and Trapping, Other Furniture Related Product Manufacturing, Miscellaneous Durable Goods Merchant Wholesalers, Taxi and Limousine Service, and Other Support Activities for Transportation.
What does this mean for your facility’s data strategy? If your company has 100+ employees and falls under Appendix B, assume your injury and illness data is now part of OSHA’s enforcement radar. This is not optional compliance — it’s the foundation of targeted inspection activity. Companies with clean data, proper recordability determinations, and documented hazard controls that reduce injury rates systematically avoid being flagged for inspection. Companies with misclassified or delayed submissions become inspection candidates regardless of actual safety performance. Building accurate recordkeeping and transparent injury reporting is now the best defense against OSHA enforcement action.
Frequently Asked Questions
Q: Which companies must submit OSHA 300 and 301 forms under the new rule?
A: Companies with 100 or more employees that fall under Appendix B are required to submit OSHA 300 and 301 forms in addition to the 300A summary, whereas companies with 250 or more employees must continue with existing requirements. iSi Environmental can help verify your company’s status and ensure compliance with OSHA’s electronic reporting requirements.
Q: Does my company need to include its legal name on OSHA injury reports?
A: Yes, inclusion of your company’s legal name is now required on all OSHA injury and illness reporting forms. This change ensures accurate identification of establishments in OSHA’s database and is a critical compliance element for all reporting companies.
Q: What industries were newly added to OSHA’s electronic reporting requirements?
A: NAICS codes for Logging, Hunting and Trapping, Furniture Manufacturing, Taxi and Limousine Services, and Transportation Support Activities were moved to require expanded reporting due to increased fatalities and DART rates. If your business falls under these industries, iSi Environmental can provide guidance on new compliance obligations.
Q: How do I determine if my company meets the 100+ employee threshold?
A: The threshold is based on your establishment’s average number of employees during the year. OSHA uses specific calculation methods outlined in 29 CFR 1904. Contact iSi Environmental for a compliance review to determine your reporting category and obligations.
Q: If we are now in Appendix B due to NAICS code changes, what additional compliance steps must we take?
A: You must now submit detailed 300 and 301 forms in addition to the 300A summary. This means auditing your injury records for accuracy and completeness. High-risk facilities should conduct a retrospective audit of the past two years of injury data to catch any misclassifications before they appear in OSHA submissions and trigger enforcement targeting. Include company legal name on all submissions. Consider working with a third party to verify recordability determinations and ensure data consistency.
💰 Dollar Anchor: A facility with 120 employees in a newly moved-to-Appendix-B NAICS code reporting 20 recordable injuries per year is now subject to detailed submission scrutiny. If an audit reveals misclassifications or underreporting, OSHA can cite recordkeeping violations ($16,550+ per error) plus expand the inspection scope based on the injury patterns revealed in the data. A company with 3–5 recordability misclassifications faces $50,000–$80,000 in settlement before any hazard-based citations. Facilities conducting pre-submission data audits to verify accuracy prevent this outcome entirely. The cost of an audit is typically $5,000–$10,000; the cost of penalties is exponentially higher.
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