Alert: Do it Now! The deadline for initial submission is December 1, 2017

Manufacturers, printing companies, and other high risk industries that had 20 or more employees (plus temps reporting to the company) on any one day during 2016 are required to submit their 2016 OSHA 300A data summary to the new OSHA Injury Tracking Application (ITA) by December 1, 2017. The OSHA 300A summary data for 2017 must be submitted by July 1, 2018. Sites that are not in high risk industries only need to submit data for any site with 250 or more employees.  There are a few exceptions: Some state run OSHA programs, such as California, have not adopted using the ITA for data submission. If you have some sites in a state with a state-run OSHA program, you likely will not have to submit the OSHA 300A data for that site yet.

If you have a one site company, this process should only take around 30 minutes. If your company forgot to make and post the 300A form in January of this year, you have some catch-up work to do. Note that the executive who signs the OSHA 300A annually, is responsible (and accountable to OSHA) to ensure the data submitted is correct. If a corporate entity decides to submit data for multiple plants through a single account, it will involve creating a batch cvs file (and significantly more time).

This list will get you going…

If your company has one or more locations that need to electronically submit data to OSHA, follow these eleven steps to complete this data submission project:

1. Explore the OSHA launch page and listed links on the topic: https://www.osha.gov/injuryreporting/index.html
2. Determine which sites in your company are required to electronically file OSHA 300A summary data to the OSHA ITA site (all sites with 20 or more people in high risk industries, such as printing or manufacturing, or only sites with 250 or more if not in a high risk industry).
3. Decide whether each site/plant will submit independently, or a corporate or division leadership person will create and upload a .cvs file with entries for each company site that is required to submit data to OSHA. (Note that you will only be able to run roll-up reports of your sites using the ITA tool, if they were entered under a single account linked to a single email).
4. Select the most appropriate NAICS code for each site (6 digits). Gather /obtain a copy of the signed OSHA 300A summary for the year 2016 (must be signed by a company executive representing the site).
5. Set-up a practice account on OSHA’s Sandbox practice version of the Injury Tracking Application. The ITA Practice Sandbox is located at: https://preview.osha.gov/injuryreporting/ita
6. Practice setting up the establishment and entering the 300A data for a plant (or creating/uploading a batch .cvs file that includes data for multiple sites/entities,  if corporate or division management will be filing for multiple sites).
7. Set-up a real account in the ITA (using the blue “Launch ITA” button top right on the OSHA info page (hyperlink in number 1 above))
8. Log into the real ITA account and set-up establishment/site(s)
9. Enter the 2016 OSHA 300A summary data (If corporate is submitting for plants, they will create and upload a .cvs file that lists each site's data separately).
10. Save/submit the data into the system (in late November). You should get a pop-up saying submitted, then email saying received (If you don’t receive both, there is a problem). In some cases you might get an email days later stating there were errors in your submission.
11. Make any needed edits (during December)
12. Finalize/Confirm the data in the ITA (mid to late December). This locks in data that likely will go public eventually. If you do this during the final days of the month, there will not be time to respond if you get an email days later stating that there were errors in the data submission you confirmed.

Note that the initial submission is due by December 1, 2017. Then companies will have till December 31 to make any needed adjustments and officially confirm the data.

I’m told that since thousands of companies are actively walking through this process right now, the system is beginning to move slowly, so don’t put this off. This is a multi-step process that may take some focused efforts.