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OSHA Needs to Improve Reporting of Summary Injury and Illness Data (300A)

Updated: Jan 10, 2023

Employers must report data on work-related injuries and illnesses to the Occupational Safety and Health Administration each year. OSHA uses the data to target high-risk workplaces for inspections.

Recordkeeping Forms

Recordkeeping forms are kept on a calendar-year basis and must be maintained at the workplace for five years and available for inspection by OSHA or the designated State agency. Three forms must be maintained to comply with OSHA Recordkeeping requirements:

What is the OSHA 300A (Summary of Work-Related Injuries and Illnesses)?

The employer is responsible for preparing an annual summary of injuries and illnesses that occurred during the calendar year. The annual summary, OSHA Form 300A, displays the totals from columns G through M of OSHA 300 Log. The summary also displays the calendar year covered, company name and address, annual average number of employees and total hours worked by all employees covered by the OSHA 300 log.

Form 300A is a separate form and does not display any personal information, as shown on OSHA 300 Log. Form 300A also makes it easier to calculate incident rates.

About 3.5 million workers suffered job-related injuries and illnesses in 2018.

But employers did not report data for more than 50% of workplaces that met the reporting criteria, so OSHA may not know which have the highest injury and illness rates. OSHA hasn't evaluated the effectiveness of its procedures to encourage and enforce compliance with reporting requirements and lacks a plan to correct deficiencies.

What GAO Found

GAO's analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years (see fig below). An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA's rule for reporting severe injuries and illnesses coincided with, and were cited by, OSHA staff as key factors explaining these fluctuations.

Number Recordkeeping Violations OSHA Cited by Fiscal Year

Employers did not report any summary injury and illness data on more than one-half of their establishments that GAO estimated met the reporting requirements (see table).

Estimated Compliance with Summary Injury and Illness Reporting Requirement

OSHA has limited procedures for encouraging compliance with this reporting requirement and for penalizing non-compliance. For example, OSHA officials told GAO that they identified nearly 220,000 employers in 2019 who may not have reported their data and mailed reminder postcards to about 27,000 of them. OSHA also cited 255 employers for failure to report their data from mid-December 2017 through September 2019 after OSHA conducted on-site inspections. OSHA uses the summary injury and illness data to target high-risk establishments for certain comprehensive inspections. Because OSHA has not evaluated its procedures, it does not know the extent to which its efforts may be improving injury and illness reporting or what other efforts it should undertake. Absent more complete information, OSHA is at risk for not achieving its objective of targeting inspections to establishments with the highest injury and illness rates.

Why GAO Did This Study

In 2018, about 3.5 million workers suffered job-related injuries and illnesses and 5,250 died on the job, according to Bureau of Labor Statistics data. Employers are required to record work-related injuries and illnesses, promptly report severe injury and illness incidents to OSHA, and certain employers are required to report summary injury and illness data electronically on an annual basis. GAO was asked to review how OSHA addresses recordkeeping violations, and implements its rule for reporting summary data.

This report examined: (1.) how and why recordkeeping violations changed from fiscal years 2005 through 2019; and (2.) the extent to which employers report summary injury and illness data and OSHA has taken steps to ensure compliance with this requirement.

GAO analyzed 15 years of OSHA recordkeeping violation data and compared OSHA and Census data to estimate how many employers complied with summary reporting requirements. GAO also reviewed agency procedures and relevant federal laws and regulations and interviewed OSHA headquarters officials and staff at seven OSHA area offices, selected for geographic dispersion and varying amounts of recordkeeping violations.

So, listen up employers! The Biden Administration has learned from the deficiencies of OSHA. They are in the process of hiring the highest number of inspectors the agency has ever seen.


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