Navigating OSHA Recordkeeping and the Injury Tracking Application: Complying with the New Requirements

OSHA; Regulations; Safety

The Occupational Health and Safety Administration (OSHA) Standard 1904.41 requires certain employers to comply with electronic submission of workplace injuries and illnesses. OSHA's oversight of recordkeeping of workplace incidents has recently become increasingly more focused.  
One significant development in OSHA's approach to recordkeeping is the implementation of the Injury Tracking Application (ITA). Launched as part of the Improve Tracking of Workplace Injuries and Illnesses rule, the ITA introduces an electronic platform for certain employers to submit their injury and illness data—i.e., their OSHA 300 logs, form 301, and 300A summary. This post will briefly review OSHA recordkeeping and the ITA, introduce incident rates and DART rates, and discuss implications for employers. 

The ITA process for electronic submission of injury and illness data to OSHA was implemented in phases. The initial requirement for certain employers to electronically submit their injury and illness summary information became effective on January 1, 2017. The final rule became effective January 1, 2024, and expanded the original rule to include the date, physical location, and severity of the injury or illness; details about the worker who was injured and how the injury or illness occurred. 
Under the final rule, OSHA requires certain employers to electronically submit their injury and illness data through the ITA. Although some employers are exempt, most long term care providers should have submitted the required data by March 2, 2024.  

Injury/Illness Rates (DART and Incidence):

OSHA recordkeeping, including the OSHA 300 logs, allows OSHA, an employer, or the general public to identify incident rates (Total Recordable Rates) and DART (Days Away, Restricted, or Transferred) rates. The DART rate is a key metric used in occupational safety and health to assess the frequency of workplace injuries and illnesses. It is a commonly used indicator to measure the impact of work-related incidents on a company's workforce. The DART rate is calculated per 100 full-time employees and is often used to compare the safety performance of different companies or industry sectors. 
The formula for calculating the Total Recordable Rate and DART Rate is as follows:

* 200,000 factor is used to standardize the rate per 100 full-time employees working 40 hours per week for 50 weeks. 

Components of the DART Formula:

  • Recordable Events:  
    • The total number of events that resulted in an employee having either Days Away from work or Restricted/Transferred due to a work-related injury or illness. 
  • Total Hours Worked by Employees:  
    • The cumulative number of hours worked by all employees during the reporting period. 

Why DART Rate Matters:

DART rates can be used by OSHA and other outside entities to assess your safety and health program, including in the following ways: 


OSHA uses the DART rate to determine which employers should be inspected under its emphasis programs. For example, OSHA’s Site Specific Targeting (SST) emphasis program uses lists of eligible companies in the following four categories: 

  • High-Rate Establishments:  
    • The SST plan selects individual establishments for inspection based on CY 2021 Form 300A data. Because average DART rates vary widely among industries, OSHA will set one DART rate for manufacturing (NAICS 31-33) and a different DART rate for non-manufacturing (all other NAICS, except construction) as objective selection criteria. This method will allow OSHA to equally target manufacturing and non-manufacturing establishments.  
  • Upward Trending Establishments: 
    • ​OSHA will identify establishments with rates at or above twice the private sector national average in CY 2019, that have continued to trend upward through CY 2021.  
  • ​Low-Rate Establishments: 
    • To verify the reliability of the Form 300A data reported to OSHA, the agency will generate a random sample of establishments with low DART rates, using the CY 2021 data.  
  • Non-Responders: 
    • ​OSHA will generate a random sample of establishments that failed to provide the required Form 300A data to OSHA CY 2021. Inclusion of these nonresponding employers is intended to discourage employers from not complying with their obligation to report injury and illness information to avoid inspection. 

Because OSHA includes both high-rate and low-rate responders, it is in the company’s best interest to accurately keep injury and illness records. 
Other businesses:

More and more often, prospective clients, buyers, partners, and subcontractors are asking for or looking at DART rate data to assess the company’s safety program. In short, your DART rate can affect your reputation for safety in the community. 

Your DART rates may be requested by an insurance carrier and affect the premiums on your workers compensation or other insurance policies. 

OSHA is increasingly focused on recording workplace injuries and has now required that the data be uploaded to OSHA’s ITA. Since this information is now readily accessible to OSHA and the public, it could have far-reaching effects and should be maintained accurately with attention to detail. OSHA has provided a list of FAQs pertaining to its ITA. 

OSHA ITA Submittal Resources:

Quick Reference ITA Coverage Table* 


Peak # of employees during the year  

11 - 19 

20 - 99 

100 or more 

Maintain OSHA records  




Submit 300A data​ to ITA 




Submit 300 and 301 data to ITA 




*This table applies to NAICS codes: 

  • ​6231 - Nursing Care Facilities;  
  • 6232 Residential Intellectual and Developmental Disability, Mental Health, and Substance Abuse Facilities;  
  • 6233 - Continuing Care Retirement Communities and Assisted Living Facilities for the Elderly;  
  • 6239 - Other Residential Care Facilities ​