As of last week, OSHA received about 214,000 electronically submitted 300A forms from 70,000 employers. Of those, some 20 to 30 percent were from establishments not required to submit them electronically. It seems a review of which employers are required to submit 300A forms electronically is in order.

Establishments with 250 or more employees are required to electronically submit their OSHA Form 300A Summary of Work-Related Injuries and Illnesses, OSHA Form 300 Log of Work-Related Injuries and Illnesses, and OSHA Form 301 Injury and Illness Incident Report electronically. Employers in designated industries, with 20-249 employees, are required to electronically submit their OSHA Form 300A Summary of Work-Related Injuries and Illnesses. Those industries that fall within this second category can be found HERE. Examples of such employers include: agriculture, forestry, fishing and hunting (NAICS code 11); Utilities (NAICS code 22); Construction (NAICS Code 23); Manufacturing (NAICS codes 31-33); and Wholesale Trade (NAICS code 42).

Two groups of employers, those with 10 or fewer employees and those who are in certain low-hazard industries are exempt from recordkeeping. The listing of partially exempt industries can be found HERE. Please note that the exemption from recordkeeping does not exempt these industries from reporting workplace fatalities, in-patient hospitalizations (not all must be reported), amputations, and eye losses. Please also note that OSHA counts all employees an establishment employed during each calendar year to determine the number of employees for purposes of these rules and their exceptions.