OSHA Initiates 300A Enforcement Program

OSHA is initiating an enforcement program that identifies employers who failed to submit Form 300A data. Annual electronic submissions are required by establishments with 250 or more employees currently required to keep OSHA injury and illness records, and establishments with 20-249 employees classified in specific industries with historically high rates of occupational injuries and illnesses.

The program matches newly opened inspections against a list of potential non-responders to OSHA’s collection of Form 300A data through the ITA and reports all matches to the appropriate OSHA area office. If the area office determines that the establishment on the list is the same establishment where the inspection was opened, OSHA will issue citations for failure to submit OSHA Form 300A Summary data.

In addition to identifying non-responders at the establishment level, the agency is also reviewing the 2021 submitted data to identify non-responders at a corporate-wide level. This corporate level review is being conducted for the nation’s largest employers. The initiative will begin in early April.

The agency is also posting ITA data as part of its electronic recordkeeping requirements for certain employers. By mid-March, 289,849 establishments had submitted their OSHA Form 300A information.

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