By Stephen Wolszczenski, Vice President of Risk Control 

A key OSHA reporting deadline is approaching for construction companies.  

In 2023, OSHA adopted a new rule requiring certain construction companies to electronically submit information to OSHA regarding job-related injuries and illnesses experienced by the company in the previous year.  

With access to this data, OSHA aims to better identify and abate hazards at specific establishments. When needed, the administration intends to interact directly with these establishments through enforcement or outreach activities to improve worker safety and health. This information will also allow OSHA to better analyze injury trends related to specific processes and hazards. 

Electronic Submission Requirements 

Under the new rules, establishments with 100 or more employees in industries OSHA has designated as “high hazard” must electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA Form 300 Log and Form 301 Incident Report. NAICS 2381 (foundation, structure and building exterior contractors) is the only construction NAICS on the high hazard list that will fall under the new requirement to provide their OSHA 300 and 301 information.   

Any construction company whose NAICS begins with a “23” and who employed 20 or more employees at any time during the previous calendar year must continue to submit their OSHA 300A Summary of Work-Related Injuries and Illnesses electronically to OSHA.  This information is to be submitted through the OSHA Injury Tracking Application portal available on OSHA’s website.   

Key Deadlines 

The electronic information must be submitted by March 2nd of each year for the previous calendar year. This electronic reporting is in addition to the requirement for construction companies who employed 10 or more employees in the previous calendar year to complete and post the OSHA Form 300A in an area visible to employees at every job site from February 1 through April 30. 

EHD is Here to Help 

As we near the start of February, we’re reminding our clients to compile and organize this information. At EHD, we can help with this process to ensure all rules and requirements are met. 

Reach out to an EHD representative today for more information.