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 03, 2026
Top 5 Remodeling Projects in 2025In the midst of the current housing affordability crisis, remodeling is capturing a growing share of the residential construction market. As remodeling continues to boom, NAHB is tracking which projects builders are tackling most frequently.
Feb 03, 2026
A 72-Year-Old Ranch Home Goes from Tear-Down Candidate to IBS SpotlightThe New American Remodel 2026 exemplifies how even a "soft remodel" can have a significant impact on a dated home. Phil Kean will put his renovated home on full display during the 2026 Builders' Show.
Latest Economic News
Feb 02, 2026
U.S. Population Growth Slows in 2025According to the U.S. Census Bureau’s latest estimates, the U.S. resident population grew by 1,781,060 to a total population of 341,784,857. The population grew at a rate of 0.5%, a sharp decline from the near 1.0% growth in 2024.
Jan 30, 2026
Bathroom Remodeling Is Most Common Project in 2025Every quarter, the National Association of Home Builders (NAHB) conducts a survey of professional remodelers. The first part of the survey collects the information required to produce the NAHB/Westlake Royal Remodeling Market Index (RMI).
Jan 29, 2026
Saving Rate Falls to 3.5% in NovemberPersonal income rose 0.3% in November 2025, following a 0.1% increase in October, according to the latest data from the Bureau of Economic Analysis. Gains were largely driven by higher wages and dividend income. However, income growth has cooled noticeably from peaking at a monthly increase of 1.1% in July 2022 to 0.3% now.