OSHA Electronic Injury and Illness Reporting

OSHA Electronic Injury and Illness Reporting is the requirement for certain establishments to submit their injury and illness records to OSHA online once a year. It builds on the recordkeeping forms employers already keep and gives OSHA, researchers and the public better data about where workers are getting hurt.

If your establishment meets the size and industry criteria, posting your OSHA 300A summary on the wall is not enough. You must also send the data to OSHA through its Injury Tracking Application (ITA) by March 2 each year, and some larger establishments in high-hazard industries must submit case-level detail as well.

What Is OSHA Electronic Injury and Illness Reporting?

The requirement is found at 29 CFR 1904.41, Electronic submission of Employer Identification Number (EIN) and injury and illness records to OSHA. It sits in Subpart E of the OSHA recordkeeping rule, Part 1904, which covers reporting information to the government.

OSHA adopted the routine electronic submission requirement in a May 2016 final rule. It was amended in 2017 and 2019, and OSHA's July 21, 2023 final rule, effective January 1, 2024, added the current requirement for certain establishments to submit Form 300 and 301 data. Key terms:

• Establishment: a single physical location where business is conducted. Coverage is decided establishment by establishment, not by company size.
• Form 300A: the annual summary of injuries and illnesses.
• Forms 300 and 301: the injury log and individual incident reports, which carry case-level detail.
• Appendix A and Appendix B to Subpart E: lists of industries, by NAICS code, that determine which establishments must submit. They are different from the partial exemption list in Appendix A to Subpart B.

Who Must Comply?

Under 1904.41(a), three groups of establishments must submit data every year:

• 20 to 249 employees in a designated industry. Establishments that had 20 to 249 employees at any time during the previous calendar year and are in an industry listed in Appendix A to Subpart E must submit Form 300A data.
• 250 or more employees. Establishments that had 250 or more employees at any time during the previous calendar year and are required to keep OSHA records must submit Form 300A data.
• 100 or more employees in a high-hazard industry. Establishments that had 100 or more employees at any time during the previous calendar year and are in an industry listed in Appendix B to Subpart E must also submit Form 300 and Form 301 data.

When counting employees, include part-time, seasonal and temporary workers. Each individual employed at any time during the calendar year counts as one employee.

Exemptions and special cases

• Partially exempt establishments. Establishments exempt from keeping records under 1904.1 (small companies) or 1904.2 (listed low-hazard industries) do not routinely submit. They must submit only if OSHA notifies them in writing.
• Submission on notice. Any employer must electronically submit Part 1904 information if OSHA notifies it to do so.
• State Plan states. The requirement applies in State Plan states too. Some State Plans go further; OSHA's FAQ notes that Minnesota requires additional private sector establishments to submit, and public sector employers should check with their State Plan.

Key Requirements

What you submit

Covered establishments submit the information from their certified 300A, including the establishment name and address, industry, annual average employees, total hours worked and the column totals. Under 1904.41(a)(4), you must also provide the Employer Identification Number (EIN) used by the establishment.

Establishments covered by Appendix B also submit the information from each 300 Log entry and each 301 incident report, with specific fields excluded by 1904.41(b)(9):

• From Form 300: the employee's name.
• From Form 301: the employee's name and address, the name of the physician or other health care professional, and the name and address of any facility where treatment was given away from the worksite.

Under 1904.41(b)(10), you may use numbers or codes as establishment names, but the submission must include your legal company name.

How you submit

Submissions go through OSHA's Injury Tracking Application. OSHA accepts data by web form, CSV upload or an application programming interface (API). It does not accept mailed or emailed submissions. A corporate office may submit on behalf of its covered establishments, and multiple establishments can be managed under one account.

Zero-injury establishments

A covered establishment with no recordable cases still has to submit its 300A data, showing zeros. If the 300 Log has no cases, there is nothing to submit for Forms 300 and 301.

Deadlines and Recordkeeping

• March 2 each year. Under 1904.41(c), data for a calendar year is due by March 2 of the following year. For example, data for calendar year 2025 was due March 2, 2026.
• Submission window. The ITA opens early in the year for the previous year's data. OSHA accepts late submissions, but a late submission is still late.
• Underlying records. The submission does not replace the paper or electronic forms. Keep the 300, 300A and 301 for five years under 1904.33, and post the 300A from February 1 to April 30.
• Certification first. The 300A you submit should match the summary your company executive certified under 1904.32.

Public data

OSHA publishes much of the submitted data on its website. According to OSHA's ITA FAQ, it removes names and other direct identifiers and withholds certain case fields such as age, sex, date hired, and emergency room and hospitalization details before release. Write case descriptions with that in mind: be factual and avoid personal details beyond what the form requires.

Common Violations and Penalties

• Assuming company size decides coverage. Coverage is per establishment. A large company can have small sites that do not submit, and a mid-sized site in a listed industry may have to.
• Using the wrong appendix. Checking only the partial exemption list in Subpart B instead of Appendices A and B to Subpart E.
• Undercounting employees. Leaving out temporary, seasonal or part-time workers when applying the thresholds.
• Not submitting zero-injury summaries. Covered establishments with no cases still must submit.
• Missing the EIN or company name. Both are required parts of the submission.
• Submitting data that does not match the log. Totals should reconcile with the certified 300A and the 300 Log.

OSHA enforces the rule during inspections. Its March 23, 2026 enforcement memo describes matching open inspections against establishments that may not have submitted their 300A data, then informing employers of the obligation and citing non-compliance where appropriate. Penalty amounts follow OSHA's standard civil penalty structure; see the OSHA penalties page for current maximums.

How to Comply: Step by Step

1. List your establishments. Identify every physical location that keeps its own OSHA records.
2. Find the NAICS code for each. Use the code that reflects the establishment's primary activity.
3. Count peak employment. For each establishment, find the highest number of employees at any time in the prior year, including temporary and seasonal workers.
4. Check coverage. Compare each site against the three thresholds and Appendices A and B to Subpart E, or use OSHA's ITA coverage application.
5. Close out your logs. Review the 300 Log, complete and certify the 300A, and confirm 301 reports are complete for every case.
6. Gather identifiers. Confirm the EIN and legal company name for each establishment.
7. Submit through the ITA. Use the web form, CSV upload or API, and keep the confirmation.
8. Calendar the deadline. Set reminders well before March 2 and before the February 1 posting date.

How SMS360 Helps

SMS360's Analytics & Reports module brings incident data into dashboards and reports, so you can review totals, check case details and spot gaps well before the submission deadline. Consistent incident records make it easier to prepare 300A totals and case-level information that match what you submit.

The same data supports ongoing measurement of lagging indicators such as your TRIR and DART rate, so year-end reporting becomes a check rather than a scramble.

Frequently Asked Questions

Who has to submit OSHA 300A data electronically?

Establishments with 250 or more employees that must keep OSHA records, and establishments with 20 to 249 employees in industries listed in Appendix A to Subpart E of Part 1904, must submit Form 300A data each year. Establishments with 100 or more employees in industries listed in Appendix B must also submit Form 300 and 301 data. Coverage is based on peak employment at each establishment during the prior year.

When is the OSHA electronic reporting deadline?

Data for each calendar year is due by March 2 of the following year. OSHA's Injury Tracking Application opens early in the calendar year. OSHA accepts late submissions, but they do not meet the deadline and can still lead to a citation.

Do I have to submit if we had no injuries?

Yes, if your establishment meets the coverage criteria. You submit 300A data with zeros. Establishments subject to the Form 300 and 301 requirement have no case data to submit if the log is empty.

Will OSHA publish my injury data?

OSHA publishes much of the submitted data on its website. It does not collect employee names or addresses, and it removes or withholds other information that could identify individual workers before release.