OSHA Proposes Recordkeeping Rule Changes

04.13.2022
OSHA form
HR & Safety

The U.S. Department of Labor is proposing changes to federal recordkeeping regulations that would add reporting requirements for some industries and require establishments to include their company name when submitting information electronically to OSHA. 

Certain employers currently submit a summary of work-related injuries and illnesses annually. In the March 28 announcement, OSHA officials said the proposed rule requires a group of employers to submit additional information. 

Employers with 100 or more employees in certain high-hazard industries would be required to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year under the proposed rule. 

Employers should already be recording much of that information, but not all employers are required to submit the information to OSHA. 

OSHA’s proposed rule also updates the classification system used to determine which industries are covered by the electronic submission requirement. 

Information Submissions

At the same time, it would remove the current requirement for establishments with 250 or more employees who are not in a designated industry to electronically submit information from their Form 300A annually to OSHA.

Requirements that establishments with 20 or more employees in certain high-hazard industries must submit information from their Form 3000A annual summary to OSHA electronically will continue as well.

“There are some concerns about the burden the increase in electronic reporting will have on smaller companies.”

CBIA’s Phillip Montgomery

“CBIA’s Safety Advisory Board believes these changes will be of little impact to large companies,” CBIA Director of Compensation Services and Safety Phillip Montgomery said. 

“In some ways it could increase accountability. However, there are some concerns about the burden the increase in electronic reporting will have on smaller companies.” 

Lost Confidentiality

Perhaps the largest concern among employers is the proposal that establishments will have to submit their company name, as the confidentiality aspect of the reporting will be lost. 

Officials with OSHA said the proposed changes to the rule would overall advance their mission of empowering workers by increasing transparency in the workforce. 

Comments about the recordkeeping rule can be submitted on the Federal e-rulemaking portal, OSHA-2021-0006. 

As a reminder, employers must post their 2021 summary of work-related injuries and illness (Form 300A) by April 30, 2022. 


For more information, contact CBIA’s Phillip Montgomery (860.244.1982).

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