Resources & Insights

OSHA’s New Rules: Electronic Recordkeeping Just Got Trickier

December 14, 2023

Gary Glader
Practice Area Leader, Safety Consulting, CCIG

Navigating the intricacies of OSHA’s evolving Electronic Recordkeeping Standard has become a critical task for employers, with recent changes reshaping reporting obligations.

New Transparency Means New Concerns for Employers

In 2016, OSHA published changes to the recordkeeping standard that required employers to submit information from their OSHA logs electronically to the agency via a website portal. The Trump administration blocked implementation of the changes until 2018. Certain requirements included in the original standard were removed, including injury-specific information from the OSHA 300 Log and 301 Form. Also deleted was a provision that would have allowed public access to the information.

Fast forward to the Biden administration, which issued a final rule in July that requires certain employers to electronically report detailed information on the 300 Log and 301 Form by March 2, 2024.

Additionally, the agency will make the information submitted electronically readily available to the public. Public access to the information is particularly troubling for employers, as previously private information concerning a company’s injuries and illnesses will now be available to the public, customers, competitors, labor unions, and other interested parties.

Accuracy is Key to Avoiding Pitfalls

What was once a straightforward task is now more complicated than ever.

Worse, different types and sizes of employers are treated differently in the revised standard that requires close examination of North American Industry Certification System (NAICS) codes and the number of employees.

Because this information will be made available to organizations that can create difficulties for the employer, particularly when customers may use the information to deny business opportunities, it is critical to understand the OSHA recordkeeping requirements to avoid inaccurate or overreporting that creates potential jeopardy for the employer.

Learn More About OSHA Recordkeeping

CCIG sponsored an OSHA recordkeeping workshop in January 2024 where all the details regarding OSHA recordkeeping and the new changes regarding electronic reporting were covered. View the workshop recording and access resources here:

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