April 9, 2026 - The Michigan Occupational Safety & Health Administration (MIOSHA) has revised Part 11. Recordkeeping and Reporting of Occupational Injuries and Illnesses, updating requirements for how businesses record and report occupational injuries and illnesses.
Here is a breakdown of the key changes and a roadmap for your compliance strategy:
The most significant change is the expansion of electronic data submission via the OSHA Injury Tracking Application (ITA).
100+ Employees in High-Hazard Industries: Under the new rules, establishments with 100 or more employees in specific high-hazard industries (including construction, as listed in the new Appendix C) must now electronically submit detailed data from Form 300 and Form 301. If you hit 100 employees at any point in the year, including temps you supervise, prepare for full 300/301 electronic submission.
250+ Employees: Large employers in industries required to keep records must continue to submit Form 300A.
MIOSHA now explicitly requires the submission of your Employer Identification Number (EIN) along with your electronic data. If you have multiple "establishments" (permanent offices or long-term projects), you may need to submit separate reports for each, rather than one company-wide roll-up.
The appendices (A, B, and C) have been updated. Even if your business wasn’t required to submit detailed logs in the past, you must check the updated Appendix C. Industries such as food manufacturing, construction, and certain retail and transportation sectors are now under closer scrutiny.
Construction relies heavily on staffing agencies and subcontractors. The updated standard clarifies "day-to-day supervision." If you provide day-to-day supervision for a temporary worker or laborer from an agency, you are responsible for recording their injuries on your log, not the staffing agency. With the new electronic submission requirements, these "temporary" incidents will now be part of your company's permanent digital safety record with MIOSHA.
The language has been updated to clarify that data is often submitted directly to OSHA’s designee (the federal ITA portal). This confirms that while MIOSHA governs the state, the digital infrastructure for reporting is unified at the federal level.
These changes move the goalpost from "summary reporting" to "detailed reporting." Here is how you should adjust your internal processes:
Because you may now be submitting Form 301, the specific details of how an injury occurred will be shared with regulators. Ensure your safety officers are writing clear, factual, and detailed incident reports. Avoid vague language; focus on the root cause and the equipment involved.
For construction companies, your safety record is often a competitive factor in the bidding process. Since detailed log data (Form 300/301) is now being submitted electronically for larger firms, your injury trends could eventually be more accessible to general contractors, clients, and insurance providers.
While Form 301 contains detailed information, MIOSHA and OSHA have protocols to scrub Personal Identifiable Information (PII) before any data is made public. However, employers should be diligent in ensuring they are only submitting the fields required by the ITA to avoid accidental disclosure of sensitive employee health data.
Ensure your recordkeeping software or manual logs are tied to the correct EIN for each establishment. If you operate multiple locations, you will need to ensure the data is organized by individual establishment, as the reporting is "per location," not necessarily a single corporate-wide dump.
The annual deadline for electronic submission remains March 2nd. However, because the data requirements are now more "granular" (moving from one summary sheet to every individual log entry), the time required to complete the submission will increase. Don't wait until the last week of February to begin the upload process.
These updates signal a move toward "data-driven" enforcement. By collecting more detailed information on how injuries happen, MIOSHA and OSHA intend to identify industry-wide trends and target inspections where they are most needed.
For employers, the message is clear: Accuracy in your daily safety logs is no longer just for internal use—it is now a public-facing compliance requirement.
Disclaimer: This post is for informational purposes and does not constitute legal advice. For the full text of the updated standard, visit the Michigan Department of Labor and Economic Opportunity (LEO) website.