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The Minnesota Occupational Safety and Health Administration (MNOSHA) requires industries to annually report work-related injury and illness data in electronic format to federal OSHA. The following are answers to common questions about MNOSHA’s adoption of the federal rule.
Who is covered by these reporting requirements?
Per MNOSHA, you must:
- Submit OSHA Form 300A data if your establishment(s) has 20 or more employees.
- Submit OSHA Form 300/301 data if your establishment(s) has 100 or more employees.
How do I determine how many employees we have?
Minn. Stat. § 182.651 Subd. 9. defines an employee as follows: “Employee” means any person suffered or permitted to work by an employer, including any person acting directly or indirectly in the interest of or as a representative of, an employer, and shall include state, county, town, city, school district, or governmental subdivision.
This means that all payroll staff, such as full time, part time, temporary, seasonal, volunteer firefighters, and paid appointed and elected officials should be included in your employee count.
What are the requirements if I have under 20 employees?
You do not need to electronically submit data to OSHA. However, you are required to:
- Keep work-related injury and illness records at your city, including OSHA 300, 300A and 301 Forms if you have more than 10 employees at any time during the last calendar year.
- Post OSHA Form 300A in the workplace annually if you have more than 10 employees at any time during the last calendar year. This Form must be completed and certified by a company executive as correct and complete and posted in the workplace where notices to workers are usually posted. It must be posted for three months, from February 1 until April 30.
Why does it say on the Federal OSHA website that only certain NAICS (North American Industry Classification System) codes/employers must submit this data?
Unlike federal OSHA, which requires only certain employers to report data, MNOSHA requires all Minnesota employers to submit data, regardless of their NAICS code. What data must be reported is based on the number of employees in your establishment. For more information, see the “Minnesota OSHA Rulemaking” webpage.
When should I submit records?
The reporting date is March 2 of the year after the calendar year covered by the form(s).
How do I submit records electronically?
First, check who in your organization is responsible for OSHA oversight or injury records. That person will likely be the one to create an account on federal OSHA’s website and submit injury and illness data annually.
Second, ensure you have a copy of the most recent year’s completed 300A Form(s) in front of you (and 300 and 301 Forms if you had 100 or more employees.
Third, go to federal OSHA’s Injury Tracking Application (ITA) to create an account and enter data (MNOSHA uses the federal ITA to collect data). A few pointers:
- Review the ITA “How To” Resources to get instructions (scroll to the bottom of the page).
- While creating an establishment, the system will ask for your North American Industrial Classification (NAICS) code. Choose code 921190, Other General Government Support. When asked if you are a public-sector entity, select Yes—Local Government.
- You can either manually enter data into a web form, upload a CSV file to process single or multiple establishments at the same time, or transmit data electronically via an application programming interface.
Still have questions?
Contact your League of Minnesota Cities Insurance Trust loss control consultant. If you’re unsure who that is, contact Loss Control Field Services Manager Kate Connell at (651) 281-1254 or kconnell@lmc.org.
