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New OSHA Electronic Occupational Injury and Illness Recordkeeping Requirements on the Horizon

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, August 9, 2022

Recorded event now available

or call 1-800-926-7926

This CLE course will advise employment counsel on the new U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) regulations related to electronic occupational injury and illness recordkeeping requirements. The panel will discuss how this differs from the prior recordkeeping requirements, who has to report, and what concerns employers may have when OSHA makes this information public. The panel will discuss comments on the regulations and what revisions to the rules may occur before final publication.


On March 28, 2022, OSHA published proposed amendments to the current injury and illness recordkeeping rule.

The proposed rule would:

  • Require establishments with 100 or more employees in certain high-hazard industries to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year.
  • Update the classification system used to determine the list of industries covered by the electronic submission requirement.
  • Remove the current requirement for establishments with 250 or more employees not in a designated industry to electronically submit information from their Form 300A to OSHA annually.
  • Require establishments to include their company name when making electronic submissions to OSHA.

Under the new rule, OSHA has stated that it will use these electronic reports to identify and respond to emerging health and safety hazards. It plans to make all but personally identifiable employee information (PII) available to the public. Once this data is made public by OSHA, it will be possible for anyone to access a company's safety data, narratives of accidents, accident counts, accident locations, injury types, and any other information contained in the Form 300 logs and Form 301 that is not considered PII.

Listen as our expert panel discusses the new proposed OSHA regulations on electronic reporting and what businesses must report. The panel will also discuss the potential liabilities and risks once OSHA makes the electronic reporting data publicly available.



  1. OSHA proposed regulations on electronic occupational injury and illness recordkeeping requirements
    1. Determining which businesses report
    2. NAICS
    3. Public disclosure
    4. Potential risks
  2. Best practices for employers


The panel will discuss these and other relevant topics:

  • What is required under the new OSHA electronic reporting rules?
  • How does OSHA determine which businesses must report under the new regulations?
  • What comments may affect the final publication of the rule?
  • How will public disclosure of electronic reporting of injury rates affect a business' liability?


Henderson, Josh
Josh Henderson

Norton Rose Fulbright US

Mr. Henderson is an Employment and Labor partner in San Francisco and Los Angeles. He represents employers in a variety...  |  Read More

Covert, Brittany
Brittany Covert

Norton Rose Fulbright US

Ms. Covert is an associate practicing in the Houston office. She joined Norton Rose Fulbright in 2018 and...  |  Read More

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