Seyfarth Synopsis: Once again, employers are required to submit OSHA Forms 300, 301 and 300A online via OSHA's Injury Tracking Application (ITA).
OSHA requires some employers to upload 2024 OSHA Form 300 log, Form 300A Summary, and Form 301 Incident Report information to its Injury Tracking Application (ITA) by March 2, 2025. Users may manually enter data to the secure ITA website, upload a CSV file to add multiple establishments at the same time, or transmit data electronically via the API (application programming interface).
Only certain employers are required to comply with the electronic submission requirements. Employers must consider the number of employees and industry classification at a specific site establishment, rather than at the entire Company.
Employers must submit Form 300A Summary data for an establishment if it meets one of the following criteria:
- 250 or more employees and is not in an industry listed in the Exempt Industries list in Appendix A to Subpart B of OSHA's recordkeeping regulation, or
- 20-249 employees and is in an industry listed in Appendix A to Subpart E.
Employers must also submit Form 300 Log and Form 301 Incident Report data for an establishment if it has 100 or more employees and is in an industry listed in Appendix B to Subpart E.
Certain State Plans (e.g. Minnesota) require additional private sector establishments to submit 300A and 300/301 data. Private sector employers in these State Plans should contact their State Plan for guidance about what is required to be submitted.
Establishments that meet any of the following criteria during the previous calendar year do not need to electronically submit their information to OSHA:
- The establishment's peak employment during the previous calendar year was 19 or fewer employees, regardless of the establishment's industry.
- The establishment's industry is listed on Appendix A to Subpart B of OSHA's recordkeeping regulation, regardless of the number of employees working at the establishment.
- The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is not on Appendix A to Subpart E of OSHA's recordkeeping regulation.
Employers unsure of their obligations can use the ITA Coverage Application to determine if they are required to electronically submit their injury and illness information to OSHA. Employers may also wish to review OSHA's Injury Tracking Application training video.
OSHA is now sharing ITA data and third party tracking services are mining it. Employers must be even more vigilant to ensure that all data they submit is accurate.
Originally published 30 January 2025
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
