This article is an overview of the new process for creating ITA data files for submittal to OSHA before March 1, 2024. There will separately be published specific articles on the tasks to help you save time. Be sure that your employer is required to do this reporting before starting this journey.
OSHA currently requires information from the Form 300A Summary report to be electronically reported using the ITA system. Beginning in 2024, the reporting requirement is being expanded to include information from the Form 300 Log report as well as the Form 301 incident report.
The FirstReport Online (FROL) web application currently includes tools to assist end users in reviewing and submitting their Form 300A Summary data through the OSHA ITA system. New tools are being rolled out to the FROL application to address the Form 300 / 301 incident data as well.
Per the OSHA ITA documentation, the data to be submitted through the ITA system is organized by establishment. In the FROL web application, establishments are referred to as locations. The remainder of this document will use the term location to refer to an OSHA establishment.
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All the data to be submitted through the ITA system comes from the location profile information and individual incident records stored in the FROL web application. Beginning in 2024, the ITA system will require the submission of 2 different data files.
The first file contains the Form 300A Summary data. The tools for preparing this type of data file have been available in the FROL web application for several years now. The second file contains the Form 300 / 301 individual incident data. The tools for preparing this type of data file are being added to the FROL web application to support the new reporting requirement in 2024. The remainder of this document will refer to the data files as the Summary data file and the Incident data file.
Not all employers / locations are required to submit their data through the OSHA ITA system. It is the responsibility of the end users of the FROL web application to appropriately classify their locations by NAICS code and size as discussed in the OSHA ITA documentation and enter that information on the FROL OSHA 300A employment data form.
ALL locations that have the NAICS code and size information entered on the FROL form will be included in the submittal files. Only those incidents that are marked OSHA Recordable on the FROL incident forms will be included in the submittal files. Individual incidents in the FROL web application are organized by location and if the corresponding location does not have the required NAICS code and size information entered, then the incident will not be included in the submittal file, even if marked OSHA Recordable.
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Within the FROL web application, OSHA ITA reporting is accomplished in 2 steps. The first step is to review all the location and incident data to ensure that everything is configured correctly for reporting and that all required information has been entered. Once the first step has been completed, the second step is to create the data files that can be submitted through the ITA system.
The data review step is accomplished using the FROL OSHA ITA readiness reports. The 3 readiness reports available through the FROL OSHA reporting feature are the Location Readiness Report, the Incident Readiness Report and the Duplicates Readiness Report.
Duplicates Readiness Report - OSHA requires that location names be unique within an employer and incident report numbers be unique within each location. The Duplicates Readiness Report looks for duplicate location names and incident report numbers and lists any items that may need to be corrected. Note that the search for duplicate incident report numbers is not limited to the report year selected on the FROL OSHA Report form. The search looks for duplicates in all report years which means that the listing of a duplicate report number may or may not be an issue. Below are some examples of duplicate report number possibilities:
All the report numbers are in years prior to 2023 - If you are preparing your data for report year 2023 and the report number "Report-31" was used in 2017 and 2019 then this is not an issue because the incident data from 2017 and 2019 has never been reported to OSHA.
One report number in a prior year - If you are preparing your data for report year 2023 and the report number "Report-31" was used in 2017 and 2023 then this is not an issue because the incident data from 2017 has never been reported to OSHA.
Duplicate report numbers in the current year - If you are preparing your data for report year 2023 and the report number "Report-31" was used for 2 incidents in 2023, then the 2023 incident data would be rejected by OSHA.
Duplicate report numbers in subsequent years - If you submit incident data for 2023 and one of the incidents uses the report number "Report-31" and then try to submit incident data for 2024 that includes another incident with report number "Report-31" then the 2024 incident data would be rejected by OSHA.
Location Readiness Report - This is the same report that has been available in the FROL web application for several years. This report provides information to ensure that locations are configured properly for reporting and that required information is available.
Incident Readiness Report - This is a new report being released to support the new incident reporting requirements beginning in 2024. This report provides information to ensure that the required incident information is ready for reporting. This report only includes incidents that are marked OSHA Recordable and includes incidents from all locations, regardless of whether the location is currently configured for reporting. There are other incident reports available in the FROL web application that can list any incidents that are not currently marked OSHA Recordable.
The Location Readiness Report and Incident Readiness Report utilize the following formatting to facilitate the review process:
Report Field Names - Field names that end in "_I" are for information only and are not included in the submittal files. Field names that end in "_R" are included in the submittal files and a value is required for the field. All other fields are included in the submittal files, but a value is not required for the field.
Report Field Values - Question Marks (?????) in a field indicates that either no value is present in a required field or that the value in the field is not valid.
If a value is not required and no value is present, the field will indicate Not Defined. For all other situations, the value in the FROL database is presented.
The FROL web application allows incidents and locations to be marked as "hidden" or "deleted" for convenience in managing the online data. For the purpose of the ITA submittal process (both the readiness reports and the submittal files) the "hidden" and "deleted" designations are ignored when selecting the data to include.
The "hidden" and "deleted" designations cannot not be used to select the locations and incidents to include in the ITA submittal files. Locations are included if the NAICS code and size information is entered on the FROL OSHA 300A employment data form. Incidents are included if they are marked OSHA Recordable and the associated location has been configured for reporting.
Summary of Important Concepts
Readiness Reports - The readiness reports are tools that are provided to assist you in preparing your data for reporting. These reports are designed to show all the location and incident data available so you can decide what should be included in the submittal files. Any deficiencies identified in the readiness reports will need to be corrected by the end user prior to creating the submittal files.
Locations included in the submittal files - Locations are included if the NAICS and Size fields are completed on the FROL 300A Employment Information form. OSHA only requires locations with certain combinations of NAICS / Size to be submitted, however, the FROL system does not attempt to enforce these requirements. If the NAICS and Size fields are completed for a location, it will be included in the submittal file regardless of whether it is required by the OSHA regulations.
Incidents included in the submittal files - Incidents are included if the corresponding location is configured for submittal, the Date of Injury is in the selected report year and the incident is marked OSHA Recordable.
FROL "Hidden" and "Deleted" - The FROL "Hidden" and "Deleted" options do not affect the data that is included in the readiness reports or the submittal files.
OSHA Rules - The OSHA regulations define the rules regarding what to submit, how it should be formatted and any additional requirements or restrictions. These rules were incorporated into the readiness reports to assist you in preparing your data for reporting, however, the rules are not used to alter or correct any data that is included in the submittal files. The end user is entirely responsibility for ensuring that their data in the FROL system complies with the OSHA requirements before creating the submittal files.
Recommended Steps
1. Review the Duplicates Readiness Report for the desired report year. Use the Manage - Setup menu to correct duplicate location names.
1a. After correcting any duplicate location names, run the Duplicates Readiness Report again. Use the incident search form to find incidents based on the report number and correct duplicate Report Numbers as required.
2. Review the Location Readiness Report and correct any deficiencies. Don't enter any NAICS code or size information for locations that should not be reported.
3. Review incidents that are not currently marked OSHA Recordable. Create an incident summary report for the desired OSHA report year with Search Yes-No 1 set to "OSHA Recordable ?" and Yes-No 1 Search Criteria set to "No". In the Change Report Column Topics section, make sure FROLID is included. Review the report to identify any additional incidents that should be marked OSHA Recordable. You can use the FROLID with the GoTo incident menu item to quickly access any incidents that need to be edited.
4. Review the Incident Readiness Report. Anything marked with Question Marks (?????) needs to be corrected. You can use the FROLID with the GoTo incident menu item to quickly access any incidents that need to be edited.
5. Once the applicable locations and incidents have been reviewed and corrected, set the ITA process fields on the employer profile form. The export process will run overnight and the zipped submittal files can be downloaded from the employer profile form the next day.
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