Complying with OSHA Requirements (SNF/AL)

Under OSHA Standard 1904.41 – Electronic submission of Employer Identification Number (EIN) and injury and illness records to OSHA, certain employers are required to electronically submit their Employer Identification Number (EIN) and injury and illness records to the Occupational Safety and Health Administration (OSHA). A cornerstone of this mandate is the Injury Tracking Application (ITA) which provides an electronic platform for employers to report injury and illness data.

Who must comply? The 2024 final rule outlines clear criteria for LTC employers required to submit data via the ITA: 

• Recordkeeping Requirements: Establishments in designated industries with 20 to 249 employees must electronically submit their injury and illness summary data (Form 300A) annually. See OSHA’s list of covered industries for details. Additionally, certain LTC employers with 250 or more employees, as well as those in high-hazard sectors, may face expanded reporting obligations. 
• Long-Term Care Operators: While some exemptions apply, most operators in this sector must submit at least partial data, reflecting the rule’s broad reach across industries. 
• Resources: OSHA has an ITA Coverage Application that helps determine your specific requirements based on your number of employees and industry classification. See ITA Coverage Application. 

The ITA Submission Process: The Injury Tracking Application is OSHA’s centralized platform for electronic submissions, streamlining the reporting process. Employers can access the ITA portal to submit their data. The process involves: 

1. Collecting Data: LTC employers must compile accurate records from OSHA Forms 300, 301, and 300A, depending on their size and industry. 
2. Submitting Electronically: Via the ITA, LTC employers upload the required information, including the newly mandated details from the 2024 rule. 
3. Verification: OSHA provides tools within the ITA to ensure submissions are complete and compliant.

For detailed guidance, visit the ITA page. As of 2025, OSHA continues to refine the platform, addressing user feedback from the 2024 submission cycle to improve accessibility and functionality.