OSHA’s New Injury Tracking Application (ITA) Deadline is December 1: How to Submit and Edit Data

This past August, OSHA officially launched its Injury Tracking Application (ITA), ending months of delays and uncertainty surrounding the compliance deadlines for OSHA’s “Improve Tracking of Workplace Injuries and Illnesses” (aka Electronic Reporting) rule. All signs currently indicate the agency’s plan to move forward with its first submission deadline of December 1, 2017.

Shortly after its launch, OSHA temporarily suspended user access to the ITA due to an apparent data breach. However, it was later determined that no breach occurred and the ITA is back online. With the initial compliance deadline now just weeks away, many employers still have unanswered questions about electronic recordkeeping, from the applicability of the rule to the record submission process itself.

One big question, which has not been widely addressed is whether and how users will be able to edit the data once it is uploaded to the ITA.

To assist companies and EHS professionals in preparing for the rapidly approaching ITA submission deadline, VelocityEHS has compiled the most useful information that OSHA has made available regarding the ITA submission process.

Who Must Submit Recordkeeping Data to OSHA ITA by December 1, 2017?

Establishments with 250 or more employees that are currently required to keep injury and illness records under the OSHA Recordkeeping Standard, as well as establishments with 20-249 employees that are also covered by the OSHA Recordkeeping Standard and operating in certain industries with historically high rates of occupational injuries and illnesses will be required to submit that data electronically.

These covered establishments must submit required data from their OSHA 300A forms (Summary of Work-Related Injuries and Illnesses for reporting year 2016) to OSHA via the ITA by December 1, 2017. This is the same data establishments are required to post in their facilities annually between February and April.

What Happens in 2018?

Next year, covered establishments with 250 or more employees must submit information from their 300A forms as well as their 300 forms (Log of Work-Related Injuries and Illnesses) and 301 form (Injury and Illness Incident Report) through the ITA by July 1, 2018.

Covered establishments with between 20 and 249 employees will still only need to submit the 300A information by that date.

What About 2019?

Beginning in 2019, and every year thereafter, covered establishments will need to submit the same information required in 2018 by March 2.

Submission Year	Establishments with 250 or more employees	Establishments with 20-249 employees	Submission deadline
2017	Form 300A	Form 300A	Dec 1, 2017
2018	Forms 300A, 300, 301	Form 300A	July 1, 2018
2019	Forms 300A, 300, 301	Form 300A	March 2, 2019

 

How do I submit data to the ITA?

Let’s review the submission process. The secure website currently offers three options for data submission:

1. Manual Data Entry: This first (and potentially most time consuming) option enables users to manually enter data into web form fields that mirror the paper form 300A.
2. CSV File Upload: The second option lets users upload a CSV file to quickly submit data for single or multiple establishments at the same time. The ITA website currently offers full instructionsfor this upload method, along with a CSV file template and sample file.
3. API Plugin: The third option allows users of recordkeeping software systems to transmit data electronically via an application programming interface (API). This method requires the use of a unique API token generated by the ITA website, and integration with your recordkeeping system that may necessitate involvement of IT staff and your software provider.

OSHA estimates that it will take a typical establishment with 20-249 employees that is required to report about 10 minutes to create an account, and another 10 minutes to enter the required information from form 300A. For typical establishments with 250 or more employees, the agency estimates that it will take the same amount of time to enter the required information from form 300A, and an additional 12 minutes to enter the required information for each injury or illness recorded on the 300 and 301 forms.

Am I required to edit my recordkeeping data as new information becomes available or as mistakes are identified?

According to the OSHA Recordkeeping Rule, employers are expected to revisit and revise their occupational injury and illness records as necessary. For instance, OSHA Standard 29 CFR 1904.33 deals with the retention and maintenance of records after they have been created and summarized. The Standard requires employers to update the entries on their OSHA 300 log and show any changes that have occurred to previously recorded cases. Therefore, during the required 5-year period for maintaining occupational injury and illness records, employers are expected to update records to account for any newly discovered cases or changes in classifications of previously recorded injuries and illnesses.

An example might be an injury initially described as a “strain” that was later formally diagnosed by a licensed physician (e.g., as tendonitis, epicondylitis, etc.), or when an injury that first involved only restricted duty results in days away from work, triggering a reclassification. In a letter of interpretation, OSHA has indicated that they would find employers who fail to update their records when applicable to be out of compliance with recordkeeping obligations.

How do I edit my data after it’s been uploaded to OSHA’s ITA?

Reviewing and revising records was a relatively straightforward matter when employers were only required to maintain records internally, but the electronic reporting obligation adds a new wrinkle for covered employers.

Let’s say an employer submits their occupational and injury records to OSHA via the ITA by the required submission deadline, but later becomes aware of errors in the data. How can they address the mistake and supply OSHA with the revised information?

OSHA’s website for the ITA contains a number of supporting documents that address these questions, including instructions and “job aids.” According to this guidance, an employer has several options for editing data submitted via the ITA, depending on the situation.

• Editing Establishment Data: If only data about the establishment itself needs to be revised, a user can navigate to the “View Establishment List” from the dropdown menu, click the name of the specific establishment to be edited, then modify the appropriate fields and click “save.” More detailed instructions and screen shots are available here.
• Editing 300A Data (In Progress): Now let’s suppose an employer has 300A data in progress (i.e., not yet submitted) on the ITA, and needs to change something before the information is submitted? In this case, they can navigate to the “View Establishment List” option, click the name of the affected establishment, and go to the “Edit 300A Summary” screen. They can then make the required edits and resave. Full instructions and screenshots are posted here.
• Editing Data After Submission: Even after you’ve submitted the data for your establishment, you still have the ability to revise it. OSHA explains that you can make changes to your data by uploading a new file. The establishments included in the new file will be updated and new submission records will be created.

It should be noted that form-specific instructions exist only for 300A data at this point in time, since that is the only data that must be received from all affected facilities by December 1, 2017. Presumably, OSHA will have additional specific instructions available for forms 300 and 301 in advance of the deadline for submission of that data on July 1, 2018. Be sure to check back on OSHA’s recordkeeping rule and ITA application pages for future updates and guidance.

Be aware that editing injury and illness data is likely to become a more pressing issue beginning in 2019, when the reporting deadline for all covered establishments changes to March 2. This change means that the time between the end of the year and the time data is due for submission will shorten, and there will be less time to identify errors and edit the data prior to submission.

Let VelocityEHS Help!

While the final rule does not require employers to adopt an electronic system to record occupational injuries and illnesses, EHS management software with the ability to export data in a standard CSV file format that meets OSHA’s specifications can significantly streamline the electronic submission process. The VelocityEHS Incident Management solution makes it easy for employers and employees to more accurately record workplace incidents, near-misses and hazards of all types, and automatically generate your OSHA forms 300, 300A, and 301. Our solution even allows users to generate properly formatted injury and illness summary reports for instant electronic submission to the ITA. With VelocityEHS, you can take the anxiety out of compliance with OSHA’s electronic reporting rule and have the tools you need to improve your incident management performance.

For more information on OSHA Recordkeeping and other compliance topics, including a variety of informative webinars, white papers, guides, articles and more, visit our Resources page.