OSHA Issues Final Rule on Injury and Illness Reporting Requirements

Safety
Published

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.

Subscribe to NAHBNow

Log in or create account to subscribe to notifications of new posts.

Log in to subscribe

Latest from NAHBNow

Membership | Leadership Meetings

Jan 14, 2026

Applications for 2026 Leadership Grants and Scholarships Now Open

NAHB is invested in professional development opportunities for its members and providing exposure to NAHB leadership meetings to help foster future leaders for the home building industry. Applications are now open for select leadership grants and scholarships for qualified members to capitalize on these opportunities.

Advocacy | Economics | IBS

Jan 13, 2026

Podcast: Home Builders and Buyers Unsettled as 2026 Begins

On the latest episode of NAHB’s podcast, Housing Developments, CEO Jim Tobin and COO Paul Lopez kick off the first podcast of 2026 looking at the state of housing, the political environment heading into a midterm year, and how builders and buyers are attempting to navigate the current market.

View all

Latest Economic News

Economics

Jan 14, 2026

Building Material Price Growth Remains Elevated in November

Residential building material prices continued to experience elevated growth, according to the latest Producer Price Index release from the Bureau of Labor Statistics. Price growth has been above 3.0% since June this year, despite continued weakness in the new residential construction market.

Economics

Jan 13, 2026

New Home Sales Rise Year-Over-Year as Prices Stabilize

The new home sector has played an increasingly important role in meeting housing demand as resale inventory remains constrained in many regions. The latest data released today (and delayed because of the government shutdown in fall of 2025) indicate that new single-family home sales continue to reflect a stabilizing market after a period of heightened volatility.

Economics

Jan 13, 2026

Inflation Steady in December

Inflation held steady in December, matching November’s reading, according to the Bureau of Labor Statistics (BLS) latest report. This December report was the first report to include a month-to-month figure since the government shutdown.