On April 5, the U.S. Department of Labor’s Occupational Safety and Health Administration announced that it is starting an enforcement program that identifies employers who failed to submit Form 300A data through the agency’s Injury Tracking Application. The enforcement program will begin in early April and was developed in response to recommendations from the Government Accountability Office to improve reporting of summary injury and illness data.

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 are required to electronically submit information from their OSHA Form 300A. This year, covered establishments were required to submit information from their completed 2021 Form 300A by March 2.

According to OSHA’s release, “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.”

The release further states, “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.”

For more information, visit OSHA’s website on Injury and Illness Recordkeeping and Reporting Requirements and Electronic Submission of Records.