b'To improve data quality, establishments will also be required to include their legal company name when makingelectronicsubmissionstoOSHAfromtheirinjury and illness records, rather than their Employer Identification Number (EIN).Previously, two (2) groups of establishments were requiredtoelectronicallysubmitinformationfrom their Form 300A annual summary: (1) establishments with20-249employeesincertaindesignated industries; and (2) establishments with 250 or more employees in industries that are required to routinely keep OSHA injury and illness records. Whats new in By Gary Auman and Lindsey Deck thefinalruleistherequirementthatestablishments of Auman Mahan & Furrywith100ormoreemployeesincertaindesignated high-hazardindustrieswillnowberequiredto electronicallysubmitinformationfromtheirOSHA OSHA ANNOUNCES FINAL RULE300and301toOSHAonceayear.Theindustries includedwerechosenbasedonindustryhazardous-REQUIRING ELECTRONIC SUBMISSIONS FOR EMPLOYERS INness and will be listed in the new Appendix B to 1904 CERTAIN HIGH-HAZARD INDUSTRIESSubpart E. As discussed above, the Final Rule sets the number of Congress intended for the Occupational Safety andemployees at 100 and will include employers that had Health Act to include reporting procedures that would100ormoreemployeesatanypointduringtheprovide the agency and the public with an understand- previouscalendaryear.Thecountwillincludeall ing of the safety and health problems worker space,full-time,part-time,temporaryandseasonal and this rule is a big step in finally realizing thatemployees. Submissions will be due by March 2 for objective. OSHA will use these dated to intervenethe previous calendar year.through strategic outreach and enforcement to reduceEmployers should be aware that OSHA will plan to worker injuries and illnesses in a highhazardpublish some of the data collected on the OSHA web-industries.site, in order to notify employers, employees, poten-~ Doug Parker, Assistant Secretary for Occupationaltial employees, employee representatives, current and Safety and Health, July 17, 2023potentialcustomers,researchersandthegeneral public to access this information and make informed decisionaboutacompanysworkplacesafetyand A new rule will now require certain employershealth record. OSHA has stated that it will not collect indesignatedhigh-hazardindustriestoelectronicallyorpublishemployeenamesoraddresses,namesof submitinjuryandillnessinformationtotheOccupa- health care professionals, or names and addresses of tionalSafetyandHealthAdministration(OSHA).facilitieswheretreatmentwasprovidediftreatment Yes,constructionisahighhazardindustryasiswas provided away from the worksite. most manufacturing. The rule, which will take effect onJanuary1,2024,includesthefollowingrequire-ments:WhiletheFinalRuleindicatesthatemployerswho Establishmentswith100ormoreemployeesin will be covered by this rule shall submit information certainhigh-hazardindustriesmustelectronicallyfromtheirForm300LogofWorkRelated submit information from their Form 300 - Log ofInjuriesandIllnessesandForm301InjuryandWork-Related Injuries and Illnesses, and Form 301IllnessIncident Reports to OSHA once ayear, the - Injury and Illness Incident Report to OSHA onceannouncement by OSHA has not yet identified what a year. information shall be submitted or the format in which it shall be filed electronically with OSHA. When this rule was initially discussed several years ago, one of therepresentationsmadewasthatthisinformation NOTE:ThesesubmissionsareinadditiontotherequiredsubmissionofForm300A-SummaryofwouldbepostedontheOSHAwebsiteandwould Work-Related Injuries and Illnesses (continued to page 27) 19'