Three dates matter every year: the Form 300A summary must be certified and posted by February 1, stay posted through April 30, and — for covered establishments — be submitted electronically through OSHA’s Injury Tracking Application by March 2. Here’s who must do what, and where companies get cited.
The cycle covers the prior calendar year’s injury and illness records. By February 1, the Form 300A annual summary must be completed, certified by a company executive, and physically posted where employee notices go. It stays posted through April 30. Establishments covered by the electronic reporting rule must also submit their data through OSHA’s Injury Tracking Application (ITA) by March 2. Posting and submitting are separate obligations — doing one does not satisfy the other.
Coverage is determined per establishment — the physical location — not company-wide headcount, which trips up multi-site companies constantly. In broad strokes: establishments with 250 or more employees that are required to keep OSHA records must submit their 300A data; establishments with 20–249 employees must submit if their industry appears on OSHA’s designated list; and establishments with 100 or more employees in designated high-hazard industries must additionally submit detailed data from their Forms 300 and 301. A zero-injury year does not exempt you — covered establishments submit zeroes. OSHA’s ITA includes a coverage tool; when in doubt, run your establishment through it rather than guessing.
The 300A must be certified by a genuine company executive — owner, officer, or the highest-ranking official on site. Inspectors check the signature block, and a coordinator’s signature where an executive’s belongs is a live citation source.
The February posting is visible and habitual; the March 2 ITA submission is neither. Every year, companies that faithfully posted still collect citations for the electronic half they didn’t know applied to them.
A company concludes “we’re under 250, we’re fine” at the corporate level while an individual plant sits squarely in the 20–249 designated-industry bracket. Coverage runs site by site.
The 300A is also where your TRIR, DART rate, and LTIR come from — the figures your customers’ prequalification portals, your carrier, and any acquirer’s data room will read. Recordkeeping accuracy isn’t clerical hygiene; misclassified cases distort every rate downstream, in both directions. Note on state plans: most mirror the federal requirements for private employers, but a few go further — if you operate in state-plan states, verify against the state’s own rule. Penalty amounts adjust annually for inflation; check OSHA’s current penalty page rather than any number frozen in a blog post.
From February 1 through April 30 each year, covering the prior calendar year’s data, in a visible location where employee notices are customarily posted — and it must be certified by a company executive before posting.
March 2, through OSHA’s Injury Tracking Application, for establishments meeting the size and industry criteria. Submitting in the ITA preview environment does not count, and posting the paper form does not substitute for submitting.
Yes — establishments that meet the coverage criteria must submit even for a zero-injury year, reporting zeroes. Coverage is about who you are, not what happened.
Employers with ten or fewer employees throughout the prior year, and establishments in partially exempt low-hazard industries, are generally exempt from routine recordkeeping — but never from reporting fatalities and serious hospitalizations, and never from keeping records if OSHA or the BLS specifically asks.
Misclassified cases distort your rates in front of customers, carriers, and buyers. A focused recordkeeping review fixes the data and the discipline behind it.
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