OSHA Issues Final Rule on Injury and Illness Reporting Requirements
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) late last week issued a final rule eliminating a requirement that establishments with 250 or more employees electronically submit information from certain OSHA forms.
These companies will no longer be required to electronically submit information on OSHA’s Log of Work-Related Injuries and Illnesses form (Form 300) and Injury and Illness Incident Report form (Form 301). They are, however, still required to electronically submit information from the Summary of Work-Related Injuries and Illnesses form (Form 300A). The final rule becomes effective Feb. 25, 2019.
Collection of 2018 information from the OSHA Form 300A began on Jan. 2, 2019. The deadline for electronic submissions is March 2, 2019.
OSHA noted that by preventing routine government collection of information that may be quite sensitive, including descriptions of workers’ injuries and body parts affected, the agency is avoiding the risk that such information might be publicly disclosed under the Freedom of Information Act (FOIA).
While NAHB generally supported OSHA’s position on Forms 300 and 301, NAHB believes that the agency did not go far enough in addressing significant issues associated with the previous rulemaking. The final rule does not address stakeholder concerns that the existing requirement to submit OSHA 300A Summary Forms includes Confidential Business Information (CBI) that must also be protected from public release. CBI is highly valuable to employers and must be protected in some fashion from public release. During the rulemaking, NAHB urged OSHA to rescind its submission requirements for 300A Summary Forms.
NAHB also disagrees with OSHA’s decision to require employers to include their Employee Identification Number (EIN) in the submission of the OSHA 300A Summary Forms. The agency’s desire to require the submission of the EIN for enforcement and research purposes is not outweighed by the potential for fraud exacted upon employers through the public release or availability of the EIN.
Notably, OSHA attempted to exclude public comments on problematic areas of the original Electronic Recordkeeping rule and failed to address stakeholder concerns about those provisions here.
The compliance date for the EIN submission is March 2, 2020, for 2019 Form 300A submissions.
NAHB is a party to active litigation on some of these objections and we hope to see a positive outcome to protect the confidentiality and privacy of NAHB members.
Latest from NAHBNow
Mar 30, 2026
Micro Markets Lone Bright Spot for Single-Family Home Building in Fourth QuarterIn a sign of ongoing affordability challenges and a tepid housing market, single-family construction fell across all geographic regions in the second half of 2025, with the exception of low-density, low-populated micro counties. Conversely, multifamily construction posted gains across all geographic regions. These are the major findings of the latest NAHB Home Building Geography Index (HGBI) for the final two quarters of 2025 released today.
Mar 27, 2026
Aging Housing Stock Keeps Demolition Activity ElevatedResidential demolition activity in 2025 dipped slightly by 0.1% compared to 2024, but remained well above pre-pandemic levels. Teardowns are widely viewed as a signal of reinvestment, often indicating where new construction is likely to follow.
Latest Economic News
Mar 30, 2026
NAHB HBGI: Micro Markets Lone Bright Spot for Single-Family Building in Fourth QuarterSingle-family construction declined further in the fourth quarter in all but sparsely populated micro counties, according to the NAHB Home Building Geography Index (HBGI).
Mar 26, 2026
State/Local Property Tax Revenue Rises Past $210 Billion in the Fourth QuarterProperty tax revenue collected by state and local governments rose for the ninth consecutive quarter according to the Census Bureau’s quarterly summary of state and local tax revenue.
Mar 25, 2026
Age of Housing Stock by StateAccording to the latest data from the 2024 American Community Survey (ACS), the median age of owner-occupied homes has reached 42 years old. The age of the housing stock is an important remodeling market indicator.