Who Must Submit OSHA 300A Data Electronically?
Imagine a safety coordinator in a bustling warehouse, staring at a freshly printed Form 300A summary. The calendar shows February, posters are up, but a nagging question lingers: does this place need to send the data online to OSHA too? The answer hinges on precise rules, not guesswork.
Electronic submission of OSHA 300A data is an establishment-level duty under 29 CFR 1904.41. You routinely submit Form 300A through OSHA's Injury Tracking Application (ITA) if your establishment had 250 or more employees at any time during the previous calendar year and is required to keep records under Part 1904, or if it had 20 to 249 employees at any time during that year and operates in an industry listed in Appendix A to Subpart E. This determines who must submit OSHA 300A electronically each year. Posting the form from February 1 to April 30 follows a separate rule entirely.
Posting the 300A Is Not the Same as Submitting It Electronically
Many mix up these obligations. Posting requires displaying the 300A summary in a conspicuous spot at each establishment where it applies, from February 1 through April 30. This alerts workers to the prior year's injury and illness totals. Submission, however, means uploading that same summary data to OSHA's secure ITA portal.
An establishment might post without submitting, or submit without posting, though most required to submit also post. Check the details on OSHA 300A posting requirements for clarity on display rules.
Use This Checklist for Your Establishment's Size and Industry
Assess your situation for the previous calendar year. As of August 2026, reflect on 2025 employment peaks and your NAICS code.
- Did your establishment employ 250 or more workers at any point in 2025? If yes, and you keep Part 1904 records, submit 300A data via ITA.
- Did it employ 20 to 249 workers at any point in 2025? If yes, confirm your 6-digit NAICS code against OSHA's Appendix A to Subpart E. Listed industries include certain manufacturing, construction, and healthcare sectors. If matched, submit.
- Are you partially exempt from recordkeeping? See below.
- Received a specific OSHA notice? Submit regardless.
Note: Establishments with 100 or more employees in industries from Appendix B to Subpart E face separate case-level reporting for 300 and 301 logs. Details appear in our companion guidance on that topic.
How OSHA Counts Employees for Submission Thresholds
Peak Employment Matters, Not Averages or Year-End Counts
OSHA looks at the highest headcount at your establishment during the calendar year. Under 1904.41(b)(2), every individual employed there counts as one employee, regardless of full-time status.
- Part-time staff add up.
- Seasonal hires during peak periods count fully.
- Temporary workers through agencies qualify if they worked at the site.
This is establishment-specific, not company-wide. A single location hitting 250 triggers duty there, even if corporate totals stay under. Learn more on calculating OSHA 300A employee numbers.
Include Your Establishment's EIN
Per 1904.41(a)(4), submissions require the Employer Identification Number (EIN) for that site. Verify it matches IRS records.
Establishments That Do Not Routinely Submit 300A Data
Partial exemptions from recordkeeping often mean no routine electronic submission. Under 1904.41(b)(6):
- 10 or fewer employees at any time during the year, company-wide (1904.1).
- Industries in Appendix A to Subpart B (low-hazard, like retail or real estate), regardless of size.
Even zero-case years require submission if thresholds met. Explore zero-case 300A needs. OSHA notifications under 1904.41(a)(3) can override exemptions.
Submission Deadlines: Always March 2 of the Following Year
Submit no later than March 2 of the year after the covered calendar year, per 1904.41(c). For 2025 data, that was March 2, 2026. As of August 2026, any required establishments that missed it must still submit through ITA.
Next up: 2026 data due March 2, 2027. Visit OSHA's live ITA page and ITA Coverage Application to confirm your status and deadlines. Late submissions remain accepted to support OSHA's data collection.
State Plans and Special OSHA Notifications
Requirements under 1904.41(b)(7) apply equally in State Plan states, like California or Michigan. Local regulators enforce federal standards, sometimes with tweaks.
OSHA may specifically notify establishments outside routine categories via 1904.41(a)(3). Watch email or mail from OSHA for instructions. Separate from routine duties, these collections ensure comprehensive national data.
How FORM 300 LOGBOOK Supports Your Recordkeeping
FORM 300 LOGBOOK streamlines OSHA compliance without overstepping. It organizes your 300 Log entries, generates accurate 300A totals, and exports PDF or CSV files for review or upload.
What it cannot do: transmit data directly to OSHA's ITA, file on your behalf, or replace Login.gov credentials, web forms, CSV uploads, or API methods. You handle official submission yourself via ITA.
Distinguish recordable injuries for logs with our guide on recordable vs. reportable injuries.
Final Accuracy Notes Before You Proceed
This outlines 29 CFR 1904.41 as verified in August 2026. Appendices, NAICS lists, and ITA procedures evolve. Confirm your 6-digit NAICS, review OSHA's current FAQs, and check State Plan rules before acting. FORM 300 LOGBOOK provides tools and guidance, not legal advice.
Match your operations precisely: one overlooked peak hire or NAICS digit can shift your duties.
Ready to Organize Your Records?
Open your FORM 300 LOGBOOK workspace at form300logbook.com/app to log incidents, tally summaries, and prepare exports. Stay compliant, step by step.