New Injury & Illness Reporting Requirements

On December 15, 2017, companies in Michigan will be required to begin reporting injury and illness information. The new regulation adopted by MIOSHA impacts all companies with 250 or more employees and that are required to keep injury and illness records. Companies will need to submit that information through the newly created Injury Tracking Application or ITA. Companies with 20-249 employees that are a part of certain industries with historically high rates of occupational injuries and illnesses are also required to submit information electronically. Companies that fall under specific North American Industry Classification System or NAICS codes cover a wide variety of industries, specifically codes: 22 Utilities, 23 Construction and 4441 Building Material and Supplies Dealers.

Companies that have 250 or more employees must electronically submit information from their OSHA Forms 300, 300A and 301. All of a company’s 2016 information is due by December 15, 2017. All of the 2017 information is due July 1, 2018. Beginning in 2019 and every year thereafter, information must be submitted by March 2. For companies with 20-249 employees, the dates previously mentioned are the same for information reporting.

For companies with 20-249 employees that are required to report, OSHA estimates that it will take an employer about 10 minutes to create an account and roughly 10-15 minutes to enter the required information from the Summary of Work-Related Injuries and Illness (Form 300A). For companies with 250 or more employees, it will take the same amount of time to create an account and to input the Form 300A information. An additional 15-20 minutes will be needed to enter Forms 300 and 301.

There is a chance that a company may be selected by the Bureau of Labor and Statistics for their Annual Survey. This annual survey is from an information gathering division and, as a company, you will have to submit the same information twice. OSHA and BLS are working to identify and minimize the burden to employers when needing to submit data to both agencies.

Below is the link to the ITA website, along with the link to the OSHA document, to help employers get started by creating their account.

https://www.osha.gov/injuryreporting/ita/

https://www.osha.gov/injuryreporting/jobaids/getting-started-in-ita.pdf

If you have any questions or concerns, please contact Matt McClintick, MITA’s Director of Safety & Compliance, at mattmcclintick@mi-ita.com, or call the MITA office at 517-347-8336.