California's Electronic Submission Requirements for Workplace Injury Records

Posted by Catherine Chukwueke | Jan 30, 2024

In California, employers are subject to stringent regulations aimed at ensuring the safety and well-being of their workforce. An important aspect of these regulations involves the electronic submission of workplace injury and illness records. This process, governed by Cal/OSHA, has specific criteria and deadlines that employers must adhere to diligently.

Submission Requirements

Employers in California fall under the electronic submission mandate if their establishments meet certain employee thresholds. Specifically, establishments with 250 or more employees are obligated to electronically submit Form 300A injury and illness data annually. Additionally, establishments with 20 to 249 employees operating in industries specified in Appendix H of Cal/OSHA's regulations must also comply with this requirement.

Submission Deadline

The deadline for electronic submission is a crucial aspect that employers must mark on their calendars. Each year, by March 2nd, covered employers must submit Form 300A data for the previous calendar year. For example, data for the 2023 calendar year should be submitted by March 2, 2024. This timeline ensures a comprehensive and up-to-date record of workplace injuries and illnesses.

Federal OSHA's Influence

The roots of California's electronic reporting requirements can be traced back to federal OSHA's initiatives. Initially introduced at the federal level, electronic submission requirements were integrated into OSHA's recording and reporting regulations. California, taking cues from federal guidelines, adopted its own state rule to align with these reporting standards.

Transition and Amendments

The transition to electronic submission in California had its nuances. Despite the absence of a finalized state rule, Cal/OSHA urged affected employers to comply with federal OSHA's directive. This proactive stance was an early indication of California's commitment to workplace safety reporting.

In response to federal OSHA's proposed amendments in 2018, Cal/OSHA proposed and approved an emergency rule to align California's recordkeeping requirements with the federal program. Subsequently, the emergency regulations were made permanent through a thorough rulemaking process.

Affected Establishments

The permanent regulations extend the electronic submission requirements to specific establishments in California. Those with 250 or more employees, unless exempted by section 14300.2 of title 8 of the California Code of Regulations, are mandated to submit Form 300A data annually. Similarly, establishments with 20 to 249 employees operating in industries listed in Appendix H of the emergency regulations must comply with the electronic reporting requirements.

California's electronic submission requirements for workplace injury and illness records underscore the state's commitment to fostering safe and secure working environments. By aligning with federal OSHA standards and incorporating them into state regulations, California ensures a unified and comprehensive approach to occupational safety. Employers subject to these requirements should not only be aware of the submission criteria but also understand the significance of timely and accurate reporting in promoting workplace well-being.

If you have any questions regarding compliance with California law, contact the Law Office of Catherine Chukwueke and schedule a consultation. We are here to help you navigate the complexities of employment law with confidence.

Disclaimer: This article has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. 

About the Author

Catherine Chukwueke

Catherine (“Cathy”) Chukwueke is the Owner and Principal Attorney of the Law Office of Catherine Chukwueke, a law firm focusing on labor and employment matters and workplace investigations. Ms. Chukwueke is passionate about helping people who have been mistreated in the workplace.

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