February 1 - OSHA Form 300A for previous calendar year must be posted in the work establishment from February 1 through April 30 of the following year.
March 2 - Affected employers must electronically submit information from their completed OSHA Forms for the previous year to OSHA, along with their Employer Identification Number (EIN) and company name, using OSHA's Injury Tracking Application (ITA).
What is the Injury Tracking Application (ITA)?
The ITA is Federal OSHA's requirement for two classes of employers to submit injury and illness data electronically using a secure website.
Who is required to submit their information to the ITA and what information must be submitted?
- Employers in certain high hazard industries listed in Part 1904, Appendix A of Subpart E, must submit injury and illness data from their OSHA Form 300A for establishments having between 20 and 249 employees at any time during the calendar year. New! Effective January 1, 2024, the NAICS codes listed in Appendix A will be updated.
- Employers who are already required to maintain injury and illness records must submit injury and illness data from their OSHA Form 300A for establishments that have 250 or more employees at any time during the calendar year.
- New! Effective January 1, 2024, an Appendix B will be added to Subpart E which will require employers with 100 or more employees at any time during the calendar year in certain designated industries to submit Form 300 and Form 301 data.
- All affected employers must submit the EIN for each establishment New! , effective January 1, 2024, along with their company name.
How is the requirement based?
The requirement to comply with the electronic recordkeeping requirements is based on the number of employees at each establishment.
An "establishment" is defined as a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities.
What is the Employer Identification Number (EIN)?
An EIN is also known as a Federal Tax Identification Number and is used to identify a business. Additional information about the EIN and how to obtain one can be found on the Internal Revenue Service (IRS) website.
What is the deadline for entering this information into the ITA?
Affected employers must electronically submit the required information from their completed OSHA Forms to OSHA no later than March 2 of the following year.
Can I edit my information after it has been submitted?
Yes, the system allows employers to edit the data for the year that is currently being collected, but only through December 31. For example, employers can edit their 2021 data (currently being collected) through the end of this year (2022). This can be done by using the following steps:
- Login and choose View Establishment List.
- Click on the establishment name link of the facility you want to edit.
- Click on Edit 300A Summary.
- Make your changes and save them.
- Re-submit the data.
Where can I find more answers to my questions regarding the ITA?
You can go to OSHA's website to get answers to frequently asked questions regarding ITA. General questions regarding recordkeeping can be directed to Ask OSH at email@example.com, our online webform, or via phone at 919-707-7876.
What is meant by recording or recordkeeping?
In the context of this discussion, "recording" or "recordkeeping" refers to the entry of information on the OSHA injury and illness log (OSHA Forms 300 and 301) by employers about work-related incidents that results in one or more of the following outcomes to an employee: death; loss of consciousness; days away from work or restricted duty; transfer to another job; and medical treatment beyond first aid. In addition, a work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums must be also be recorded.
What is meant by reporting?
"Reporting" refers to the requirement for employers to report to OSH any work-related fatality, in-patient hospitalization, amputation or loss of an eye within specified periods of time.
- In-patient hospitalization is a formal admission to the in-patient service of a hospital or clinic for care or treatment.
- An amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached. Amputations do not include avulsions (tissue torn away from the body), enucleations (removal of the eyeball), deglovings (skin torn away from the underlying tissue), scalpings (removal of the scalp), severed ears, or broken or chipped teeth.
- Loss of an eye is the physical removal of the eye. This includes enucleation and evisceration.
What is considered medical treatment?
The definition of "medical treatment" means the management and care of a patient to combat disease or disorder. For the purposes of the recordkeeping standard, medical treatment does not include:
- Visits to a physician or other licensed health care professional solely for observation or counseling;
- The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or
- "First aid" as defined below.
What is considered first aid?
The definition of "first aid" means the following:
- Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
- Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
- Cleaning, flushing or soaking wounds on the surface of the skin;
- Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
- Using hot or cold therapy;
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
- Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
- Using eye patches;
- Removing foreign bodies from the eye using only irrigation or a cotton swab;
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
- Using finger guards;
- Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
- Drinking fluids for relief of heat stress.
What resources are available to assist employers?
A-Z Safety and Health Topics
Training and Outreach Services
Presentations on a variety of related recordkeeping topics are available to assist employers in training their staff. These include bloodborne pathogens, occupational noise exposure and recordkeeping. Each of these presentations should be modified to address site-specific conditions and hazards. These pre-recorded webinars on recordkeeping and recording, occupational noise exposure, and bloodborne pathogens can also be accessed at any time.
In addition, the education, training and technical assistance bureau provides free online safety and health training and outreach services (i.e., speaker's bureau requests, safety booths) upon request.
The NCDOL Library offers free safety and health videos (including streaming video services) and related research assistance on consensus standards (i.e., ANSI, NFPA, NEC).
The consultative services bureau provides free and confidential onsite consultation regarding worksite safety and health hazards.
Which Standards Apply?
OSH has adopted the following standards which are applicable to recording and reporting in North Carolina. Note: Please also check the standards information and activity webpage to see if there has been any recent or upcoming regulatory activity on this topic.
29 CFR Part 1904, featuring but not limited to:
- 1904.1 - Partial exemption for employers with 10 or fewer employees
- 1904.2 - Partial exemption for establishments in certain industries
- 1904.3 - Keeping records for more than one agency
- 1904.4 - Recording criteria
- 1904.5 - Determination of work-relatedness
- 1904.6 - Determination of new cases
- 1904.7 - General recording criteria
- 1904.8 - Recording criteria for needlestick and sharps injuries
- 1904.10 - Recording criteria for occupational hearing loss
- 1904.30 - Multiple business establishments
- 1904.32 - Annual summary
- 1904.35 - Employee involvement
- 1904.36 - Prohibition against discrimination
- 1904.39 - Reporting fatalities, hospitalizations, amputations, and loss of an eye
- 1904.41 - Electronic submission of EIN and injury and illness records to OSHA
- Subpart B, Appendix A - Partially Exempt Industries
- Subpart E, Appendix A - Designated Industries for 1904.41, Annual Electronic Submission
Other Applicable Standards
The Which OSHA Standards Apply webpage can also help identify other standards that may be applicable to your worksite.
Note: OSH automatically adopts all recordkeeping standards for application in North Carolina when published in the Federal Register in accordance with 13 NCAC 07A. 0301(a).
- Report to the OSH Division within eight hours after the death of an employee as a result of a work-related incident.
During working hours (weekdays, 8 a.m. to 5 p.m.), call 1-800-625-2267 or 919-779-8560. After working hours (5 p.m. to 8 a.m.), weekends or holidays, call State Capitol Police at 919-733-3333.
Work-related injury involving one or more of the following:
- Any in-patient hospitalization of one or more employees*
- Any work-related amputation
- Any work-related loss of an eye
Report to the OSH Division within 24 hours of the incident. Call 1-800-625-2267 or 919-779-8560. Any in-patient hospitalization of one or more employees, any work-related amputation, and any work-related loss of an eye may also be reported through the online accident reporting form.
*Note: For any incidents resulting in the in-patient hospitalization of two or more employees after working hours, weekends or holidays, call State Capitol Police at 919-733-3333.
What if the fatality, in-patient hospitalization, amputation, or loss of an eye does not occur during or right after the work-related incident?
If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization, amputation, or loss of an eye occurs within 24 hours of the work-related incident, then you must report the event. If the fatality occurs after more than 30 days of the work-related incident, or if the in-patient hospitalization, amputation, or loss of an eye occurs after more than 24 hours after the work-related incident, then you do not have to report the event. However, you must record the event on your OSHA injury and illness records, if you are required to keep OSHA injury and illness records.
Where can I learn more?
- Memo (COVID-19) - Updated Interim Enforcement Response Plan for Coronavirus Disease provides guidance for recording COVID-19 illnesses along with guidance for handling COVID-19-related complaints, referrals, and severe illness reports in workplaces.
- Standards Notice: SN 75 - Public Sector Establishments for Recordkeeping clarifies how public sector employers can maintain the OSHA 300 logs for compliance inspections.
- Operational Procedure Notice: OPN 128 - Public Sector Surveys and Inspections establishes and implements a public sector survey process and inspection program as authorized by NCGS 95-133 and 95-148 to target for inspection those public sector employers with a high rate of recordable work-related illnesses or injuries.
- Compliance Directive: CPL 02-00-135 - Recordkeeping Policies and Procedures Manual establishes policies and provides clarification to ensure uniform inspection procedures are followed when conducting inspections to enforce the January 19, 2001 final rule for Occupational Injury and Illness Recording and Reporting Requirements.
- Reporting Workplace Accidents provides requirements for reporting certain workplace accidents to the OSH Division.
- Industry Guide 48 - OSHA Construction Industry Standards Requiring Programs, Inspections, Procedures, Records and/or Training provides requirements for standards related to recordkeeping in construction.
- Industry Guide 49 - OSHA General Industry Standards Requiring Programs, Inspections, Procedures, Records and/or Training provides requirements for standards related to recordkeeping in general industry.
- Industry Guide 50 - OSHA Agriculture Standards Requiring Programs, Inspections, Procedures, Records and/or Training highlights the requirements of standards related to recordkeeping in agriculture.
- Industry Guide 53 - OSHA Shipyard Employment Standards Requiring Programs, Inspections, Procedures, Records and/or Training highlights the requirements of standards related to recordkeeping in shipyard employment.
- Industry Guide 54 - OSHA Marine Terminal Standards Requiring Programs, Inspections, Procedures, Records and/or Training provides requirements for standards related to recordkeeping at marine terminals.
If you would like to receive interpretive guidance on this or any other OSH standard or topic, you can submit your questions using the Ask OSH web form, by e-mail to firstname.lastname@example.org or by calling 919-707-7876.
Frequently Asked Questions
Are the record retention requirements for the COVID-19 log different than the record retention requirements under 29 CFR Part 1904 for OSHA Forms 300, 300A, and 301, or the equivalent forms?
NCDOL repealed the Emergency Temporary Standard for Healthcare effective March 4, 2022. As a result, the record retention requirements for COVID-19 do not include the COVID-19 log.
COVID-19 related illnesses that are work related and meet the general recording criteria, would be recordable. Under 29 CFR 1904.33(a), an employer must retain the OSHA 300 Log, the privacy case list (if one exists), the 300A annual summary, and the OSHA 301 Incident Report forms for five years following the end of the calendar year that these records cover.
Are the reporting requirements for a work-related fatality or in-patient hospitalization due to COVID-19 different from other causes of work-related fatalities or in-patient hospitalizations?
No. NCDOL repealed the Emergency Temporary Standard for Healthcare effective March 4, 2022. Due to the ETS being repealed, the reporting of COVID-19 related illnesses that result in hospitalizations or fatalities would now be covered under 1904.39.
Additional COVID-19 compliance memorandums and documents can be found under the Learn More tab on the NCDOL COVID-19 safety and health topic page.