Covered Establishments In All States Must Now Submit OSHA Electronic Reports

The following is an article overview. Click here to view the full compliance brief.


On April 30, 2018, the Occupational Safety and Health Administration (OSHA) announced it will require all establishments affected by the electronic reporting rule to submit their 2017 data to OSHA by July 1, 2018.

This announcement clarifies the requirement for establishments in states with an OSHA-approved plan. These establishments must submit electronic reports, regardless of whether the state has ratified or incorporated the electronic reporting rule into its OSHA state plan.

Action Steps

Establishments in all states, including those with an OSHA-approved state plan, should prepare to submit electronic reports by July 1, 2018. Affected establishments can accomplish this by:

• Becoming familiar with the requirements in the electronic reporting rule; and
• Transitioning their OSHA records to an electronic format approved by the Injury Tracking Application (ITA).


  • • The electronic reporting rule now applies to all affected establishments, including establishments in states with OSHA-approved plans.
  • • It does not matter whether the state has ratified the electronic reporting requirements.
  • • The OSHA ITA is currently available and accepting reports on OSHA 300A forms with 2017 data.

Important Dates

December 31, 2017

Due date for first OSHA electronic reports through ITA (submit 2016 data)

July 1, 2018

Due date for second OSHA electronic reports through ITA (submit 2017 data)

Please reach out to us if you have any questions.

This compliance update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.