The Recordkeeping Policies and Procedure Directive that took effect early 2025 requires certain employers to submit detailed work-related injury and illness data electronically. It expanded the definition of hazardous industries and added more obligations for some businesses.

The rule clarifies the Occupational Safety and Health Administration’s (OSHA’s) stance on hazardous workplaces and adds updates that reflect regulatory changes.

What Employers Should Do Now

Until further changes are made, employers must ensure compliance with the current directive.

Here are key actions to take:

  • Post OSHA Form 300A: Employers with 11 or more employees during the 2024 calendar year must display Form 300A from February 1 to May 1, 2025, in a location visible to employees, such as a break room or bulletin board unless they are in an exempt industry. Companies with multiple worksites must complete a separate 300A form and post it in a visible area at each worksite.
  • Determine whether new reporting obligations apply. If they do, prepare to submit records electronically by March 2, 2025.

The OSHA Form 300A should contain a summary of all the work-related injuries and illnesses that came up during the previous year, whether a business had any or not.  A recordable incident includes any work-related injury or illness resulting in death, loss of consciousness, days away from work, restricted job duties, or medical treatment beyond first aid. Health conditions such as fractures, chronic diseases, cancer, or punctured eardrums also need to be logged if they are related to work and diagnosed by a health professional.

Recordable incidents also include injuries like contaminated needlestick wounds, cases where employees are medically removed from a worksite due to OSHA health standards, positive tuberculosis diagnoses after being exposed in the workplace, and employees experiencing hearing loss with a significant shift in hearing levels confirmed by a test.

Some states have an agency that enforces OSHA. If you conduct business in one of these states, please be aware that there might be different record-keeping requirements.

Keeping accurate records helps promote safer work environments and ensure compliance with OSHA regulations.

Expectations Moving Forward

It remains unclear how the new administration will impact these regulations. Although the future of electronic recordkeeping requirements remains uncertain, employers must continue complying with OSHA regulations.

For over 30 years, UniqueHR has helped businesses with their HR tasks, compliance, and safety questions. For a free consultation, please contact us at 800.824.8367 and we’ll be glad to assist you. We’re here to help!

This communication is for informational purposes only; it is not legal, tax or accounting advice; and should not be acted upon as such.