OSHA Injury & Illness Electronic Reporting Deadline Under 2 Weeks Away

Dealerships required to electronically file 2023 employee workplace injury and illness records with the Occupational Safety and Health Administration (OSHA) must do so by March 2, 2024.

OSHA injury and illness reporting requirements depend on the type of dealership and number of employees working at a single “establishment” or rooftop. OSHA defines an establishment as "a single location where business is conducted or where services or industrial operations are performed." The following categories of dealerships must record and report employee workplace injury and illness:

• Commercial truck dealerships with 20 or more employees working at a single establishment must electronically submit OSHA Form 300A- Annual Summary of Work-Related Injuries and Illnesses
• Commercial truck dealerships with 100 or more employees working at a single establishment, in addition to submitting OSHA Form 300A- Annual Summary of Work-Related Injuries and Illnesses, must electronically submit case-specific information from OSHA Form 300 Log and OSHA Form 301 Incident Report
• Light-duty dealerships with 250 or more employees at a single establishment must electronically submit OSHA Form 300A- Annual Summary of Work-Related Injuries and Illnesses
• Light-duty dealerships with fewer than 250 employees at a single establishment must annually record workplace injuries and illnesses but are not required to file electronically with OSHA
• All dealerships must report worker fatalities within eight hours and worker amputations, eye losses, or hospitalizations within 24 hours.

Electronic filing must be done using OSHA's Injury Tracking Application (ITA). See OSHA’s FAQs on the ITA submission process. A North American Industry Classification System (NAICS) number is required for filing: commercial truck dealerships are NAICS 42311; light-duty dealerships are NAICS 44111. 

Source: NADA

For NHADA Workers' Compensation Trust Members:
NHADA Workers’ Compensation Trust members will have the peace of mind that work-related injury or illness data will be tracked, reported, and filed accordingly with OSHA regulations. NHADA WCT will provide our members with the reports to keep on file (Form 300) and to post (Form 300A). NHADA WCT will also file the injury and illness data electronically to OSHA for our WCT members who are required to do so. We will contact those members that we think should be filing electronically annually in January for the required information.

Employers with 250 or more employees and employers with 20-249 employees classified in certain high-risk industries; NAICS code 8113 Commercial Truck and Equipment, 4413 Automotive Parts, Accessories and Tire Stores, and 4442 Lawn and Garden Equipment and Supplies Stores.

Most employers don’t need to submit injury and illness data to OSHA electronically but these forms need to be completed and kept on file for at least 5 years following the year that the data covers.

For more information, see:

• NHADA WCT OSHA Guidance
• OSHA’s Tutorial on Completing the Recordkeeping Forms
• OSHA’s FAQ on Revised Recordkeeping Requirements
• OSHA’s FAQ on Injury and Illness Reporting
• Guidance for OSHA's Injury and Illness Recordkeeping Rule
• OSHA’s Website on Injury Reporting