Electronic Reporting Gives Healthcare Employers the Nudge They Need to Protect Their Own

Electronic Reporting


In the United States the Occupational Safety and Health Administration (OSHA) recently announced their new electronic reporting requirements for US workplaces.  Beginning July 2017, most US employers will – for the first time ever – have to submit their injury and illness logs (OSHA 300 Logs) to the OSHA.  Since healthcare as an industry has the highest rates of injury and illness, twice as high as any other industry, this new requirement is intended to have a great positive effect on healthcare workers.  Healthcare employers that submit their data now have the ability to compare themselves to other facilities of their type, develop interventions to prevent injuries and illness, and target departments and procedures that carry unacceptable risk.  Essentially this allows healthcare workplaces to set their own workplace safety goals based on real benchmark data and to formulate action to prevent occupational exposures to hazards, including infectious disease.

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This spring (2016) the Occupational Safety and Health Administration (OSHA) announced its new requirements under the OSHA Recordkeeping Standard (20 CFR 1904) including – for the first time ever – requiring employers of greater than 250 employees to submit their OSHA Injury and Illness Logs (300 Logs) to the Agency electronically.1  For the first time, the nation will have access to occupational injury and illness data giving us the opportunity to drive efforts for safer workplaces.

The agency states:

This simple change in OSHA’s rulemaking requirements will improve safety for workers across the country. One important reason stems from our understanding of human behavior and motivation. Behavioral economics tells us that making injury information publicly available will “nudge” employers to focus on safety. And, as we have seen in many examples, more attention to safety will save the lives and limbs of many workers, and will ultimately help the employer’s bottom line as well. Finally, this regulation will improve the accuracy of this data by ensuring that workers will not fear retaliation for reporting injuries or illnesses.1

The new reporting requirements will be phased in over two years:

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Impact on Healthcare

Since the Bureau of Labor Statistics (BLS) estimates that healthcare – especially inpatient healthcare facilities – have an estimated 6.4 work-related injuries and illnesses for every 100 full-time employees, its incidence ranks two times higher than any other industry, including manufacturing and construction.2 BLS data up to this point has been based on voluntary data coming in to the agency from selected employers in selected industries.  As such, the current statistics that are available may very well be a grave underestimation of the real risk faced by those working in healthcare.

This new OSHA requirement will finally lead way to more accurate data.  It will also provide a better picture of what is happening in US workplaces and how we can work to prevent occupational exposures, illness, and injury.

Public Opinion on New Requirements

Safety and health professionals, injury and infectious disease epidemiologists, and labor organizations applaud this long overdue requirement and give accolades to OSHA putting something so meaningful into effect.  Having access to real injury and illness data allows advocates, researchers, and practitioners to build programs, interventions, and educational materials that reflect real world risk and prioritize tasks and challenges based on real data.

Opponents declare that this new requirement will put an undue administrative burden on already strained occupational / employee health departments.  With this criticism in mind, the agency has put together a timetable to guide employers through this process and help them estimate exactly how much additional time it will require – ranging from 20 minutes each year to a couple of hours depending on employer size and numbers of incidents.3

Since healthcare is hyper aware of confidentiality of its patients, the agency assures them the same holds true for their workers. OSHA states that it has “effective safeguards in place to prevent the disclosure of personal or confidential information contained in the recordkeeping forms and submitted to OSHA”.

Relevance to Infection Prevention and Control

Patient infections are required to be recorded and reported externally (to local Departments of Health, the Centres for Disease Control or both) in most instances.  We know the extreme burden this type of morbidity and mortality places on overall public health and the vitality of the national economy.  Employee or occupational infections, while they may be recorded internally by their places of employment, are not for the most part, reported externally.  While we may have a handle on a few occupational illnesses, such as tuberculosis (TB), which is required to be reported to Departments of Health, we have no idea what the burden of occupational illness and infection is as a whole.  This is because those cases that are recorded internally are never reported externally.  Until next year, that is.

With measurement comes action.

With action comes prevention.

There is an overwhelming hope among occupational health professionals who work in healthcare, that this requirement will shed light on occupational illness and infection so that we can collectively identify where they are occurring, what the most prevalence pathogens are, what actions we need to take to control them, and how we can prevent them in the future.  With measurement comes action. With action comes prevention.  There is no doubt that preventing occupational illness and infection in healthcare makes both healthcare workers and patients safer.


  1. Final Rule Issued to Improve Tracking of Workplace Injuries and Illnesses. Occupational Safety and Health Administration.  https://www.osha.gov/recordkeeping/finalrule/
  1. Inspection Guidance for Inpatient Healthcare Settings. Occupational Safety and Health Administration. https://www.osha.gov/dep/enforcement/inpatient_insp_06252015.html Accessed June 16, 2016.
  1. Final Rule to Improve Tracking of Workplace Injuries and Illnesses
Frequently-Asked Questions. Occupational Safety and Health Administration. https://www.osha.gov/recordkeeping/finalrule/finalrule_faq.html
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Dr. Amber Hogan Mitchell
Dr. Mitchell is the International Safety Center’s President and Executive Director.  The Center distributes the Exposure Prevention Information Network (EPINet®) to hospitals to measure occupational exposures to sharps injuries and other blood and body fluid exposures.  Dr. Mitchell's career has been focused on public health and occupational safety and health related to preventing infectious disease.  She has worked in the uniformed services, public, private, and academic sectors.  She is also the founder and president of The Public’s Health.  A consulting business that focuses on health and safety as a means to increase business vitality and longevity.    Dr. Mitchell began her career as the first OSHA National Bloodborne Pathogens Coordinator and has received several Secretary of Labor Excellence awards for her work on bioterrorism and public preparedness.  She holds a Doctor of Public Health (DrPH) degree from the University of Texas School of Public Health and a Master’s in Public Health from The George Washington University.  She is Certified in Public Health as a member of the very first CPH cohort offered by the National Board of Public Health Examiners.