Electronic Submission of Workplace Injury and Illness Records
Employers in California that have establishments meeting one of the requirements below are required annually to electronically submit Form 300A injury and illness data:
- All establishments with 250 or more employees, unless specifically exempted by section 14300.2 of title 8 of the California Code of Regulations.
- Establishments with 20 to 249 employees in the specific industries listed in Appendix H of Cal/OSHA's regulations regarding occupational injury and illness records.
The deadline for submission each year is March 2nd, and employers covered by the electronic submission requirements must submit their Form 300A data for the previous calendar year. For example, employers must submit their Form 300A data for the 2019 calendar year by March 2, 2020.
See federal OSHA's Injury Tracking Application website for information and instructions on electronic submission.
Information on Electronic Reporting Rulemaking
Employers in states regulated by federal OSHA have been required to electronically submit certain records of occupational injuries and illnesses. The electronic submission requirements, along with the incorporation of an existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses, were added to federal OSHA's recording and reporting regulations found in the Code of Federal Regulations, title 29, part1904.
On April 30, 2018, federal OSHA posted a trade release requiring all affected employers to submit injury and illness data in the federal OSHA Injury Tracking Application online portal, even if the employer was covered by a state plan that had not completed adoption of their own state rule. Therefore, even though California had not yet adopted its own state rule, Cal/OSHA advised affected employers to comply with federal OSHA's directive to provide Form 300A data covering calendar year 2017 by July 1, 2018.
On July 27, 2018, federal OSHA posted a trade release proposing to amend its recordkeeping regulation by rescinding the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injury and Illness Incident Report). These establishments would continue to be required to submit information from their Form 300A (Summary of Work-Related Injuries and Illnesses) covering the previous calendar year.
On October 18, 2018, Cal/OSHA issued an amended notice of proposed emergency action to amend sections 14300.35 and 14300.41 of title 8 of the California Code of Regulations. The purpose of the amendments was to conform California's recordkeeping requirements to the federal OSHA program. The Office of Administrative Law approved the emergency action on November 1, 2018.
On May 10, 2019, Cal/OSHA issued a notice of proposed rulemaking to make these emergency recordkeeping requirements permanent. The Office of Administrative Law approved the regular rulemaking on December 11, 2019.
The approved permanent regulations extend the requirements under the emergency regulations for establishments in California described below to submit Form 300A data each year. Establishments described below are required to submit Form 300A data covering the previous calendar year annually by March 2. These establishments should follow the instructions posted at federal OSHA's ITA website:
- All establishments with 250 or more employees, unless specifically exempted by section 14300.2 of title 8 of the California Code of Regulations
- Establishments with 20 to 249 employees in the specific industries listed in Appendix H of the emergency regulations.