NGFA published a new guidance document to provide members with an overview of the Occupational Safety and Health Administration’s (OSHA) final amended e-recordkeeping rule for injury and illness that took effect on Jan. 1, 2024. The OSHA Electronic Recordkeeping Rule Guidance Document provides an outline of important issues related to injury and illness data that NGFA member companies may wish to revisit in light of the new rule.

The first deadline for the latest information required to be submitted under this rule is March 2. OSHA has established a secure website, known as the Injury Tracking Application (ITA), which offers three options for data submission: 1) manually enter data into a webform; 2) upload a CSV file to process single or multiple establishments simultaneously; or 3) transmit data electronically via an application programming interface (API).

As noted in the guidance document, employers might consider reviewing their injury/illness reporting policies to evaluate how they are reported.

Under this rule, OSHA requires establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year. Notably, the new rule updates the list of employers considered to be in “high-hazard” industries and creates new obligations for some employers. One positive aspect of the final rule is that the grain, feed, processing and milling industries have been removed from the list of high-hazard industries.

Establishments with 20 to 249 employees in certain industries will continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year. All establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation will also continue to be required to electronically submit information from their Form 300A to OSHA annually.

For more information regarding the requirements for different industries and a brief history of the rule, summarized in the guidance document, visit