Reminder: Post Your OSHA 300A by February 1 and Keep It Posted Through April 30

Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. (Certain low-risk industries are exempted.) The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Be sure to eliminate personally identifiable information from the data prior to submission. Find detailed instructions on OSHA's website.

Know Which Establishments Are Also Required to Report Electronically by March 2

In addition, OSHA collects work-related injury and illness data from establishments through the Injury Tracking Application (ITA). By March 2, 2025, establishments that meet certain size and industry criteria are required to electronically submit to OSHA, through the ITA, injury and illness data from their OSHA Form 300A, 300, and 301. More information can be found on OSHA’s website.

Not all companies are required to report electronically using the ITA.

Under the recordkeeping regulation, which was revised effective January 1, 2024, Form 300 and 301 electronic submission requirements include establishments with 100 or more employees in designated high-hazard industries. These industries include (but aren’t limited to):

• Construction

• Manufacturing

• Healthcare

• Transportation

• Food and Beverage Manufacturing

• Warehousing and Storage

• Utilities

• Agriculture

The regulation requires establishments to include their company name when making electronic submissions to OSHA, which then makes the data publicly available in a searchable online database. (Note: whether OSHA makes the data publicly available has flip-flopped from the Obama to the Trump to the Biden Administrations; so, stay tuned for future developments).

OSHA determined which industries were “high risk” by examining industries’ total recordable cases (TRC), Days Away, Restricted, or Transferred (DART) rates, and the number of fatalities that occurred in each industry. OSHA concluded that those industries with a TRC of 3.5, a DART rate of 2.25 per 100 employees, or a fatality rate of 5.7 deaths per 100,000 full-time-or-equivalent employees were “high risk.”

Certain industries are also required to submit data from annual 300A logs:

• OSHA requires all establishments with 250 or more employees at any time during the previous calendar year, which are already required to keep records under the recordkeeping regulation (i.e., they are not exempt from OSHA recordkeeping regulations), to submit this data.

• Establishments with 20-249 employees that are in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904.