As we enter 2025, it’s time to once again focus on an important requirement from the Occupational Safety and Health Administration (OSHA). Employers with 10 or more employees are required to post the OSHA 300A form from February 1 to April 30, 2025. This annual posting ensures transparency in workplace injury and illness data for the previous year. In addition, many employers must electronically submit the OSHA 300A data by March 2, 2025.
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| OSHA 300A Form |
The OSHA 300A form is a summary of the injury and illness information that was recorded in the OSHA 300 log throughout the past year (2024). It plays a key role in workplace safety, helping employers analyze and reduce hazards in their operations. It’s important to remember that COVID-19 is considered a recordable and reportable illness if it is confirmed, work-related, and results in days away from work. In these cases, it would be logged as a respiratory illness. However, if an employee requests that their name not appear on the log for privacy reasons, employers must comply as per 29 CFR 1904.29(b)(7)(vi) and treat it as a privacy case.
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| OSHA 300 must be filled out as the year progresses |
If you need guidance in completing the OSHA 300A form, we’ve got resources to help you out. We partnered with Keevily Spero & Whitelaw to create a webinar that walks you through the steps for both the OSHA 300 and 300A forms. You can find the webinar on our YouTube Channel or watch the video below. Remember, covered employers are required to maintain accurate records of serious occupational injuries and illnesses and tally the totals at the end of each year for the OSHA 300A form. The data should be used by employers to evaluate workplace safety and make improvements to reduce risks. Keep in mind that the OSHA 300A form must be posted until April 30, 2024, and retained for five years. During this time, employers are also required to update the log as new information becomes available.
Electronic Submissions – March 2, 2025, Deadline
OSHA’s final rule, which took effect on January 1, 2017, requires certain employers to submit injury and illness data electronically. OSHA has provided a secure website for submitting this data. If you are required to submit your OSHA 300A information, be aware that there’s a login procedure that took effect in October 2022. Hopefully, you've handled this process previously. The OSHA Injury Tracking Application (ITA) helps to determine if your establishment is required to electronically submit 300A and 300/301 data through the ITA. You can watch a tutorial video on how to use the ITA to submit your data. Submissions must be completed by March 2, 2025, and OSHA began collecting data starting January 2, 2025.
You must submit 300A data if your establishment meets one of the following requirements:
- 250 or more employees and is not in an industry listed in the exempt industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904, or
- 20-249 employees and is in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904.
YOU MUST also submit 300/301 data if your establishment(s) has 100 or more employees and is in an industry listed in Appendix B to Subpart E of 29 CFR Part 1904. What does this mean for our industry? If you are in the industry of Architectural, Engineering, and Related Services you are exempt. However, for Construction, Remediation, or Waste Management Services that meet the size requirements (20 to 249 employees), you are required to submit your OSHA 300A information electronically.
Ensure you’re compliant with OSHA’s posting and reporting requirements; if you need any assistance or clarification, don’t hesitate to reach out. We’re here to help!
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| Construction Site |
2025 OSHA Penalty Updates What You Need to Know
In 2025, OSHA updated the penalty structure as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. Each year, OSHA adjusts civil penalty amounts to account for inflation, ensuring penalties maintain their deterrent effect and reflect current economic conditions. This year is no different, with the penalty adjustments now updated for 2025 based on the latest inflation data.
Purpose of the Update
The information contained in this update supplements OSHA’s existing penalties and debt collection guidelines, which can be found in Chapter 6 of the Field Operations Manual (FOM). The updated tables provided in this memorandum reflect the penalty amounts for the calendar year 2025, corresponding to adjusted figures in OSHA Information Systems (OIS). These annual adjustments allow employers and safety professionals to access the most current penalty information and ensure compliance with OSHA regulations.
Background
This annual update follows the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, which was enacted on November 2, 2015. This act builds upon the original Inflation Adjustment Act of 1990 and the 1996 Debt Collection Improvement Act to strengthen the impact of civil monetary penalties. The Inflation Adjustment Act requires two key actions by regulatory agencies:- Perform a "catch-up" adjustment of civil penalties (completed through an interim final rule in 2016), and
- Implement subsequent annual adjustments for inflation by January 15 of each year.
For 2025, the cost-of-living adjustment multiplier is 1.02598, based on the Consumer Price Index for All Urban Consumers from October 2024. This multiplier is applied to the previous year's penalty amounts and rounded to the nearest dollar. The adjustment ensures that both minimum and maximum penalties set forth under the Occupational Safety and Health Act (OSHA) and the Field Operations Manual (FOM) remain consistent with inflation.
Minimum and Maximum Penalty Amounts for 2025
To give you a clearer picture, Table 1 outlines the updated penalty amounts for various types of violations:
| Type of Violation | Penalty Minimum | Penalty Maximum |
|---|---|---|
| Serious | $1,221 per violation | $16,550 per violation |
| Other-Than-Serious | $0 per violation | $16,550 per violation |
| Willful or Repeated | $11,823 per violation | $165,514 per violation |
| Posting Requirements | $0 per violation | $16,550 per violation |
| Failure to Abate | N/A | $16,550 per day beyond the abatement date (up to 30 days max) |
Note: For repeated other-than-serious violations, the penalty starts at $472 for the first repeat offense, increasing to $1,182 for the second and $2,364 for a third repetition.
Gravity-Based Penalty (GBP) System
The Gravity-Based Penalty (GBP) is used to determine the severity of violations and assess penalties accordingly. The gravity of a violation is categorized into high, moderate, or low based on the risk it presents:
- High Gravity: $16,550 penalty
- Moderate Gravity: Penalties range from $9,457 to $14,187
- Low Gravity: $7,093 penalty
For serious violations, the GBP is determined by a combination of severity and probability, as shown in Table 2:
| Severity | Probability | GBP | Gravity | OIS/GRAVITY Code |
|---|---|---|---|---|
| High | Greater | $16,550 | High | 10 |
| Medium | Greater | $14,187 | Moderate | 5 |
| Low | Greater | $11,823 | Moderate | 5 |
| High | Lesser | $11,823 | Moderate | 5 |
| Medium | Lesser | $9,457 | Moderate | 5 |
| Low | Lesser | $7,093 | Low | 1 |
For other-than-serious violations, only minimal severity is assigned. However, if the Area Director determines a higher penalty is necessary for deterrence, the maximum penalty of $16,550 may be applied.
Serious Willful Penalty Reductions
When calculating penalties for serious willful violations, employers may be eligible for penalty reductions based on the size of their workforce. The reductions are shown in Table 3 below:
| Number of Employees | Percent Reduction |
|---|---|
| 10 or fewer | 80% |
| 11-20 | 60% |
| 21-30 | 50% |
| 31-40 | 40% |
| 41-50 | 30% |
| 51-100 | 20% |
| 101-250 | 10% |
| 251 or more | 0% |
These reductions are applied after considering other factors such as the company’s history of violations and overall safety performance.
Final Thoughts
As OSHA updates penalties each year to keep pace with inflation, employers must remain informed and compliant. These adjustments not only ensure that penalties maintain their deterrent effect but also encourage safer workplace practices. Staying on top of OSHA’s evolving regulations and penalty structures is essential for companies operating in high-risk industries.
If you have questions about these updates or need assistance navigating OSHA’s penalty framework, feel free to reach out for further guidance.
