Introduction
Under OSHA Standard 1904.41 - Electronic submission of Employer Identification Number (EIN) and injury and illness records to OSHA, certain employers are required to electronically submit their Employer Identification Number (EIN) and injury and illness records to the Occupational Safety and Health Administration (OSHA). This mandate, part of the broader push for improved workplace safety transparency, has gained momentum in recent years. A cornerstone of this effort is the Injury Tracking Application (ITA), introduced through the "Improve Tracking of Workplace Injuries and Illnesses" rule. The ITA provides an electronic platform for employers to report injury and illness data, marking a significant shift toward greater accountability and accessibility of workplace safety information.
This article explores OSHA recordkeeping, the ITA’s role, and its implications for LTC employers, including key metrics like the Days Away, Restricted, or Transferred (DART) rate.
History
The journey toward electronically submitting injury and illness data began with the "Improve Tracking of Workplace Injuries and Illnesses" rule, first issued by OSHA in May 2016. The rule aimed to enhance the tracking of workplace incidents and boost transparency by making certain data publicly available. The initial requirement for electronic submissions took effect on January 1, 2017, rolled out in phases to ease the transition for employers.
The most significant update came with the
Final Rule, announced by the Department of Labor and effective January 1, 2024. This expanded the scope of the original regulation, requiring detailed reporting from employers in high-hazard industries. The updated rule mandates the inclusion of specifics such as the date, physical location, and severity of each injury or illness; details about the affected worker; and a description of how the incident occurred. One year into its implementation, the 2024 rule has solidified OSHA’s commitment to data-driven safety oversight, with 2025 as a critical year for assessing its impact.
Who Must Comply?
The 2024 final rule outlines clear criteria for LTC employers required to submit data via the ITA:
- Recordkeeping Requirements: Establishments in designated industries with 20 to 249 employees must electronically submit their injury and illness summary data (Form 300A) annually. See OSHA’s list of covered industries for details. Additionally, certain LTC employers with 250 or more employees, as well as those in high-hazard sectors, may face expanded reporting obligations.
- Long Term Care Operators: While some exemptions apply, most operators in this sector must submit at least partial data, reflecting the rule’s broad reach across industries.
- Resources: OSHA has an ITA Coverage Application that helps determine your specific requirements based on your number of employees and industry classification. See ITA Coverage Application.
The ITA Submission Process
The Injury Tracking Application is OSHA’s centralized platform for electronic submissions, streamlining the reporting process. Employers can access the ITA portal at
osha.gov/injuryreporting/ita to submit their data, typically due by March 2 of each year for the prior calendar year’s records. The process involves:
- Collecting Data: LTC employers must compile accurate records from OSHA Forms 300, 301, and 300A, depending on their size and industry.
- Submitting Electronically: Via the ITA, LTC employers upload the required information, including the newly mandated details from the 2024 rule.
- Verification: OSHA provides tools within the ITA to ensure submissions are complete and compliant.
For detailed guidance, visit the
ITA page. As of 2025, OSHA continues to refine the platform, addressing user feedback from the 2024 submission cycle to improve accessibility and functionality.
Injury and Illness Rates: Understanding DART and Incidence
Tracking workplace safety metrics is essential for compliance and performance evaluation. Two key indicators stand out:
- Incidence Rate (Total Recordable Rate): This measures the total number of recordable incidents per 100 full-time employees, offering a broad view of workplace safety.
- DART Rate (Days Away, Restricted, or Transferred): A more focused metric, the DART rate assesses the severity of incidents by tracking those resulting in days away from work, restricted duties, or job transfers. Calculated per 100 full-time employees, it highlights the tangible impact of injuries and illnesses on the workforce.
The DART rate is widely used to benchmark safety performance across companies and industries. For LTC employers subject to ITA reporting, maintaining a low DART rate not only reflects a safer workplace but also aligns with OSHA’s goals of reducing severe incidents. As data from 2024 submissions become publicly available in 2025, LTC employers can expect increased scrutiny of their DART rates, making accurate recordkeeping more critical than ever.
Looking Ahead in 2025
One year after the 2024 final rule’s implementation, LTC employers are adapting to its demands while OSHA evaluates its effectiveness. The expanded data requirements have heightened transparency, allowing stakeholders—from regulators to workers—to better understand workplace safety trends. For LTC employers, compliance goes beyond avoiding penalties; it’s an opportunity to leverage ITA data for internal safety improvements.
As we move deeper into 2025, staying informed about OSHA’s evolving standards and mastering the ITA process will remain essential. By prioritizing accurate recordkeeping and proactive safety measures, LTC employers can meet regulatory demands while fostering a safer, more accountable workplace. For any questions, please email
regulatory@ahca.org.
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