Two dates run your year. February 1. March 2. Miss either one and a citation lands on your desk.
Here's the short answer for anyone scanning: post your Form 300A annual summary in a visible workplace spot from February 1 through April 30, then file the same data electronically through the OSHA Injury Tracking Application by March 2. The full Form 300 log stays at your facility all year. Records stick around for five years past the year they cover.
Sounds tidy. It isn't. The 2024 electronic submission rule changed who has to file Forms 300 and 301 by name, which industries got pulled into the high-hazard list, and how state plans interpret the federal floor. A meat processor in Iowa files different paperwork than a hospital in California — even when the injury count is identical.
This guide walks through every date that matters, what each form does, who's exempt, and the penalty math when something slips. Pair it with the broader osha 300 log excel reference if you need column-by-column recording instructions.
Before you dig in: this isn't legal advice. Federal OSHA sets the floor. Your state plan or industry-specific standard can — and often does — go further.
February 1, 2026: Form 300A (annual summary) must be physically posted in a workplace common area. Stays up through April 30.
March 2, 2026: Form 300A electronic submission due via OSHA's Injury Tracking Application (ITA) — required for 250+ employee establishments and for 20-249 employee establishments in designated high-hazard industries.
March 2, 2026 (2024 rule): Forms 300 and 301 case detail submission due for establishments with 100+ employees in select designated industries — first applied to CY 2023 data, filed in 2024.
Every covered employer has to take the prior calendar year's recordable injuries and illnesses — every entry on Form 300 — and roll the totals onto Form 300A. That summary goes up by February 1. Not the second. Not "sometime in February." The first.
It needs to stay posted somewhere employees actually walk past. Break room. Time clock wall. Main entrance bulletin board. Tucked inside a binder on the safety manager's bookshelf doesn't count.
The summary is a one-pager. Total cases. Days away. Restricted duty days. Death count. Injury versus illness breakdown across five categories. Establishment information. Average employee count and total hours worked across the year — those two numbers let inspectors calculate your DART and TRIR rates instantly.
A company executive — someone with authority, not just the safety coordinator — has to sign it. That signature is the legal certification that the data is accurate. Falsifying any of it is a separate federal violation with criminal exposure attached, not just a paperwork penalty.
Worth knowing: the 300A doesn't list employee names, addresses, or the specific case details. That's by design. Employees can ask to see the underlying Form 300 confidentially, but the public-facing summary only shows aggregate counts. Protects worker privacy without hiding the company's overall safety performance.
Three months on the wall. That's the window. After April 30 you can take it down, but you can't destroy it — that record lives in your files for five more years. If OSHA shows up in October asking for last year's 300A, you'd better produce it within four business hours.
This one trips people up because it's newer than the posting rule and the eligibility criteria keep shifting. Here's the current state for the 2026 filing cycle (covering CY 2025 data).
If your establishment averaged 250 or more employees at any point during 2025, you file Form 300A electronically through the osha establishment search system's companion ITA portal by March 2. Doesn't matter what industry. The threshold is headcount.
If your establishment had 20 to 249 employees AND falls into one of OSHA's designated high-hazard industries — construction, manufacturing, healthcare, warehousing, certain retail, agriculture, utilities, transportation — same March 2 deadline applies. The full list runs to about 70 NAICS codes.
One sneaky trap: the 20-employee threshold is the average across the year, not the peak. Companies that spike to 30 employees for a busy season but average 18 across the year can argue exemption from this tier. Companies that average 22 but think of themselves as small still have to file. Run the math from payroll records before deciding.
Another quirk worth pointing out: "establishment" and "company" aren't the same. A parent corporation with 5,000 employees spread across 40 small offices files based on each office's headcount — most likely none of them hit 250 individually. Conversely, a single 280-employee plant inside a much larger parent organization still triggers the filing threshold all on its own.
OSHA's January 2024 final rule changed the game for larger employers in high-hazard sectors. Used to be that only Form 300A went up to ITA. Now Forms 300 and 301 case detail go too — if you fit the criteria.
Establishments with 100 or more employees in designated industries — the list includes things like animal slaughtering and processing, sawmills, certain wood product manufacturing, beverage manufacturing, iron and steel mills, motor vehicle manufacturing, nursing care facilities, and warehousing. Run your NAICS code through the OSHA designated industries list to be sure.
If you're covered, you submit anonymized 300 log entries and the full 301 incident report data — minus employee identifying information — for every recordable case from the prior calendar year. Same March 2 deadline as the 300A submission. First filing was March 2, 2024 covering 2023 data.
Names go. Addresses go. The job title stays. Date of injury stays. What the injury was, where on the body, how it happened — all that stays, because that's the public health data OSHA is collecting. The agency publishes establishment-level summaries on a public-facing dashboard. Your competitors can see your recordable rate. Your potential hires can see it. So can plaintiff's attorneys.
Not every business has to keep these logs. Partial exemptions exist for two reasons.
If your company had 10 or fewer employees at all times during the previous calendar year — across every establishment, total headcount — you're exempt from routine Form 300/300A/301 recordkeeping. You still have to report fatalities within 8 hours and severe injuries (hospitalization, amputation, eye loss) within 24 hours. That obligation never goes away.
OSHA maintains a list of low-hazard NAICS codes — many retail, finance, real estate, professional services categories — that are exempt regardless of headcount. If you're a CPA firm with 800 employees, you don't keep a 300 log. If you're a barbershop with two chairs, you don't either. Check the partial exemption list before assuming you're covered or not — some surprising industries are on it (book stores, museums) and some surprising ones aren't (used car dealers).
A case is recordable when it meets all three threshold conditions — work-related, new case (not aggravation of a prior recorded case), and resulting in one of the general recording criteria.
Death. Days away from work. Restricted work or job transfer. Medical treatment beyond first aid. Loss of consciousness. Significant injury or illness diagnosed by a physician.
First aid is the line that catches people. A bandage? First aid, not recordable. Steri-strips? First aid. Stitches? Recordable — that's medical treatment. Eye flush in the break room? First aid. Eye flush plus prescription drops? Medical treatment, recordable. The full first-aid list is in 29 CFR 1904.7(b)(5)(ii) — read it once and tape it inside the safety binder.
Work-relatedness has its own gray zone. An employee twists an ankle in the parking lot walking to their car at lunch. Recordable? Depends. If the parking lot is company-owned and the employee was on a paid break, yes. If it's a public lot or the employee was off the clock, usually no. The work-related rules at 29 CFR 1904.5 spell out the company-premises and travel-status exceptions case by case.
The single biggest source of misrecording: managers who don't want a recordable on their stats quietly classify a stitches case as "first aid" or pressure an employee to skip medical treatment. Both are violations. The recordkeeping rule is about what should have happened medically — not what actually happened because someone delayed care.
If you want to drill on these distinctions, the osha training walkthroughs cover recordkeeping scenarios in the same format used in the certification exams.
Two more recording rules catch employers off guard. Privacy concern cases — sexual assault, HIV, mental illness, intentional self-harm, certain needlestick injuries — get recorded but with the employee name replaced by "privacy case" on the 300 log. The case is still counted in the 300A totals; only the name is suppressed.
And there's the 180-day cap. Days-away and restricted-duty counts max out at 180 calendar days combined. A worker out 200 days only gets logged as 180. The actual time off doesn't change for workers' comp purposes, but the OSHA log entry stops counting at the 180-day ceiling.
Pull all 300 log entries from the closing year. Verify every entry has correct days-away counts, restricted-duty days, and case classification (injury vs illness category).
Roll totals onto Form 300A. Calculate average annual employees and total hours worked. Get the company executive signature.
Physical posting begins in employee common area. Stays up through April 30.
Electronic filing of 300A (and 300/301 case detail for 100+ employee covered industries) via OSHA's Injury Tracking Application portal.
Remove the 300A from the wall but keep it filed. Begin maintaining current year's 300 log entries as cases occur — within 7 days of each recordable event.
After 5 full years past the end of the calendar year a record covers, you can dispose of those Form 300/300A/301 records. Earlier disposal violates 29 CFR 1904.33.
OSHA's Injury Tracking Application sits at osha.gov/injuryreporting. First time? You'll create an ITA account tied to your business identity. Second year and beyond, you log into the existing account.
Manual entry — type each data field directly into the web form. Fine if you have one or two establishments and small case counts.
CSV upload — download the OSHA-provided CSV template, fill it from your HRIS or safety management system export, upload the file. Best for medium employers with 5 to 50 establishments.
API submission — system-to-system filing for enterprise employers. Requires development work but eliminates manual handling. Most major EHS software platforms (Cority, Intelex, EHS Insight, Enablon, VelocityEHS) have ITA API integrations built in.
Save the confirmation email. Save the PDF receipt. If OSHA's system ever loses your filing — and it has happened in past cycles — that receipt is your defense. The agency has been clear: "we didn't receive it" is not an acceptable excuse, but "here's the timestamped confirmation showing we did submit it" is bulletproof.
Twenty-two states plus Puerto Rico run their own OSHA-approved state plans. Federal rules set the floor; state plans can add more. Several do.
Same February 1 / March 2 framework, but Cal/OSHA also requires the IIPP (Injury and Illness Prevention Program) to be maintained alongside the 300 log. Reporting thresholds for serious injury reporting are tighter — a serious injury (hospitalization, amputation, loss of an eye) gets reported within 8 hours, not 24.
Adopted federal recordkeeping rules in 2024 with some clarifications. The state requires Form 300A posting from February 1 through April 30 and matches the federal ITA submission deadline. State-specific guidance differs on some recordkeeping interpretations for healthcare and agriculture.
Indiana adopted the federal rule with minor administrative deviations. Oregon OSHA generally tracks federal recordkeeping but publishes its own determination letters interpreting borderline recordable scenarios — those interpretations matter if you're operating in the state.
Practical advice: if you operate in a state-plan state, read your state plan's recordkeeping FAQ each January. Don't assume federal guidance is the final word.
Multi-state operators have an extra layer of headache. A trucking company with depots in Texas (federal OSHA), California (Cal/OSHA), and Washington (DOSH) follows three slightly different rules at three sites. The 300 logs are the same form, but the reporting timelines for severe injuries vary, and the state plans publish their own clarifying letters that don't always match each other. Build a state-by-state matrix once and update it annually.
One overlooked detail: privately-owned establishments in federal jurisdictions follow federal OSHA. State and local government employers in federal-only states (like Texas, Florida, Alabama, Pennsylvania) often aren't covered by OSHA recordkeeping at all — they answer to state safety boards instead. Confirm your jurisdiction before assuming the federal rules apply.
This is the average — not the year-end headcount, not the peak. Sum the total number of employees on payroll for each pay period of the year, then divide by the number of pay periods. Seasonal employers especially flub this one because they post a peak number instead of an average. Inspectors recalculate it from your tax forms when they audit.
Total productive hours — exclude vacation, holiday, sick leave, and other non-work paid time. Most payroll systems will run a report that excludes paid-but-not-worked hours. If you submit "total paid hours" instead, your TRIR will look artificially low and OSHA's data quality checks may flag it.
A case can only be counted once. Death takes priority over days-away. Days-away takes priority over restricted duty. Restricted duty takes priority over "other recordable." Double-counting a case across columns is the most common 300A error. Each row of 300 should map to exactly one column on 300A.
Illness columns: skin disorders, respiratory conditions, poisoning, hearing loss, all other illnesses. Everything else is an injury. Hearing loss alone trips up manufacturing — a Standard Threshold Shift confirmed by a physician with average hearing at or above 25 dB is recordable as a hearing loss illness, not an injury.
OSHA's compliance officers see the same mistakes year after year. Avoiding them isn't hard once you know what they're looking at.
February 2. The 300A goes up. That one-day lag is a citable violation. Doesn't matter that it's only a day. The standard says February 1. Set a calendar reminder in January for the 25th — that gives a week of cushion to handle signatures, printing, and posting.
The safety manager signed the 300A. They're not a company executive. Cited. The signature has to be from an owner, an officer of the corporation, the highest ranking company official at the establishment, or the immediate supervisor of the highest ranking official. Job titles like "EHS Director" don't cut it unless that person sits on the executive team.
One company, eight locations. You can't file one combined 300A — you file eight separate ones, one per establishment, each posted at its own location. "Establishment" means a single physical location where business is conducted. Headquarters offices, branch offices, factories, distribution centers all count separately.
Stitches counted as first aid. Prescription medication counted as first aid. Restricted duty counted as days-away (or vice versa). Each of these creates a 300A that doesn't match the underlying 300 — and when an inspector recalculates, the discrepancy becomes the citation.
The biggest myth about recordkeeping is that it's a once-a-year project. It isn't. Every recordable case has to be entered on Form 300 within seven calendar days. Form 301 (or its equivalent — workers' comp first report works in many states) also within seven days.
If a case develops over weeks — say, a sprain that becomes a surgery six weeks later — the original entry gets updated as days-away or restricted-duty counts accrue. Updates are made until the case is closed (employee returns to full duty, leaves the company, or reaches 180 days of restricted/away status, whichever comes first).
Some employers run quarterly self-audits — compare 300 entries against workers' comp filings, OSHA-300-equivalent reports from supervisors, and any reported near-misses. Discrepancies get caught and corrected before the year-end roll-up. Cheap insurance against a January scramble.
Need to validate your understanding before exam time? The osha 30 test covers the recordable-or-not scenarios the same way OSHA structures its compliance training, and an osha certification program will reinforce these distinctions if your role requires more depth.