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
Jul 10, 2026
Plenty of Building Systems Predict High-Performance Envelopes. Here's One That Proved It.Building-envelope performance claims appear in every construction system's specs. But how those systems hold up in the real world is what matters to builders and home buyers.
Jul 10, 2026
NAHB’s Monthly Update Features Landmark Housing Legislation HighlightsThe talking points this month include information about how NAHB helped secure the passage of a historic housing bill.
Latest Economic News
Jul 10, 2026
2025 New Single-Family Starts by Census DivisionPersistently high mortgage rates, elevated costs for builders, and ongoing supply-side constraints continued to weigh on single-family construction in 2025.
Jul 09, 2026
Existing Home Sales Slowed in JuneAfter reaching a five-month high last month, existing home sales pulled back in June as record-high home prices and elevated mortgage rates weighed on buyers. This monthly volatility reflects the sensitivity of home buyer demand to mortgage rate changes.
Jul 09, 2026
Remodeling Market Sentiment Remains in Positive Territory in Second QuarterIn the second quarter of 2026, the NAHB Remodeling Market Index (RMI) posted a reading of 61, down one point compared to the previous quarter. The RMI has remained in the low 60s consistently over the past year.