*Correction (January 29, 2024): An earlier version of this article did not include the Hawaii Occupational Safety and Health Division’s list of low-risk industries that are exempt from reporting requirements. We regret the omission and updated the article to reflect the addition.

The Occupational Safety and Health Act (OSHA) and the Hawaii Occupational Safety and Health Division (HIOSH) requires many employers with more than ten employees to keep a log of workplace injuries and illnesses and post a summary annually from February 1 to April 30. Some companies with less than ten employees in the previous calendar year and companies in low-risk industries are exempt from the reporting requirements. OSHA and HIOSH have a list of low-risk industries that are exempt from the reporting requirements (each referred to as “Appendix A to Subpart B”). Companies exempt from the OSHA and HIOSH forms may still need to complete the forms if they are informed in writing to do so by the Bureau of Labor Statistics, OSHA, or HIOSH. These forms must be kept for five years. There are multiple reasons for the recordkeeping requirements. The data helps OSHA and HIOSH measure its performance and helps inspectors target workplace hazards that hurt workers. Recordkeeping also helps employers to implement safety and health programs and prevent future hazards.

As of January 2, 2024, certain establishments are required to electronically submit information to OSHA from their injury and illness recordkeeping forms annually. Data from the previous calendar year’s Form 300A Summary of Work-Related Injuries and Illnesses, Form 300 Log of Work-Related Injuries and Illnesses, and Form 301 Injury and Illness Incident Report must be electronically submitted through the Injury Tracking Application (ITA).

Certain establishments are exempt from the ITA submission process. Establishments that meet any of the following criteria during the previous calendar year do not need to submit their information to OSHA electronically:

• The establishment’s peak employment during the previous calendar year was 19 or fewer employees, regardless of the establishment’s industry;
• For establishments subject to OSHA’s administration, the establishment’s industry is listed in Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the number of employees working at the establishment and for establishments subject to HIOSH’s administration, the establishment’s industry is listed in Appendix A to Subpart B of HIOSH’s recordkeeping regulation, regardless of the number of employees working at the establishment; or
• The establishment had a peak employment of between 20 and 249 employees during the previous calendar year, AND the establishment’s industry is not on Appendix A to Subpart E of OSHA’s recordkeeping regulation.

The ITA has begun accepting 2023 injury and illness data submissions. Employers can use the ITA website to set up an account and submit their 2023 data. Employers must submit the information by March 2 of the calendar year after the year covered by the forms (for example, by March 2024 for the forms covering calendar year 2023). The due date to complete this submission is March 2, 2024. If the submission due date of March 2 has passed, employers that meet the reporting requirements but failed to do so must still submit the required recordkeeping data through the ITA and can do so until December 31. The maximum penalty for violating posting requirements is $15,625 per violation.

Also, remember that the HIOSH requires all Hawaii employers to report serious injuries and illnesses to their office as follows:

• • Within eight hours after the death of an employee from a work-related incident and within 24 hours of:
  • inpatient hospitalization of an employee
  • employee’s amputation
  • employee’s loss of an eye as a result of a work-related incident
  • property damage of over $25,000 as a result of a work-related incident.

When the HIOSH office is closed, the (808) 586-9102 telephone number will allow you to leave a phone message. For the message to be considered officially reported, all information in 29 CFR §1904.39(b)(2) must be provided on the answering machine message.

HIOSH is offering free in-person OSHA Recordkeeping Workshops (For Forms 300, 301, and 300A).

Learn who is required to maintain OSHA recordkeeping forms, when an injury or illness becomes “recordable,” how to fill out the forms, what’s in OSHA’s January 1, 2024, Recordkeeping Standard update, what are the consequences of non-compliance, and where to find additional help.

Workshops will be held on Thursdays, January 18, January 25, February 1, February 8, and February 15, 2024, 8:30 am - 11:30 am at the HIOSH Training Room, 830 Punchbowl Street, Room #427, Honolulu, HI 96813

For additional details or to register, call (808) 586-9100 or email dlir.hiosh.ct@hawaii.gov.

Space is limited to 20 participants per workshop.