OSHA Initiates Enforcement Program on Form 300A Submissions

On April 5, OSHA announced it was initiating an enforcement program to identify “employers who failed to submit Form 300A data through the agency’s Injury Tracking Application.”

The program will match newly opened inspections against a list of potential entities that did not submit their required Form 300A data and report any matches to the OSHA area office with jurisdiction over the entities. If the area office determines the establishments are in fact a match, OSHA will issue citations for failing to submit Form 300A to the agency.

As we recently reported, OSHA has recently released an NPRM to Improve Tracking of Workplace Injuries and Illnesses, which requires entities with 100 or more employees to electronically submit Form 300A (as well as Forms 300 and 301) on an annual basis to the agency. CWS will monitor this issue and plans to file comments on the NPRM.