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
Feb 10, 2026
Planning for IBS? Schedule a Stop at NAHB HQNAHB HQ has something for everyone. All registrants can participate in enrichment sessions, learn about NAHB membership, and network with attendees. NAHB members will have exclusive member-only areas with giveaways, snacks, charging areas, and more.
Feb 09, 2026
House Passes NAHB-Supported Major Housing PackageThe House this evening approved the Housing for the 21st Century Act, a major bipartisan housing package that takes much-needed steps toward addressing our nation’s critical lack of housing.
Latest Economic News
Feb 10, 2026
Credit Card Balances Rise in Q4 2025Overall consumer credit continued to expand in the fourth quarter of 2025, with growth in both nonrevolving and revolving credit. Nonrevolving credit, primarily student and auto loans, accounts for 74% of total outstanding consumer credit, while revolving credit, largely credit card balances, makes up the remaining 26%.
Feb 10, 2026
Weaker Demand, Unchanged Lending Conditions for Residential Mortgages in Fourth QuarterLending standards for most types of residential mortgages were essentially unchanged but overall demand was weaker in the fourth quarter of 2025, according to the recent release of the Senior Loan Officer Opinion Survey (SLOOS).
Feb 09, 2026
Lower Rates Lift Mortgage Activity at Start of the YearMortgage application activity rose sharply in January, driven primarily by a surge in refinancing activity as mortgage rates declined to a new low. The Mortgage Bankers Association’s (MBA) Market Composite Index, a measure of total mortgage application volume, increased 12.9% from December on a seasonally adjusted basis and was 61.3% higher than a year earlier.